ABSTRACT
In my research, ‘The Hidden, True Civil Law Jurisdiction in North America and Factors of Distance’, I uncovered a little-known Civil Law jurisdiction that has often escaped the discovery of legal scholars. While the legal community typically acknowledges Louisiana, my jurisdiction of residence, and Quebec as the sole Civil Law systems in North America, my investigation brought to light the existence of a smaller, yet extremely significant, Civil Law jurisdiction. This jurisdiction, Saint Pierre and Miquelon, challenges common perceptions due to its unique status. Located as an archipelago south of Newfoundland, Canada, it remains a part of French territory despite its geographical isolation. Its legal system is French Civil Law, making it arguably the purest Civil Law jurisdiction in North America.
There is a fascinating legal infrastructure on these islands, including their own court of first instance and a specialized court that functions for appeals, demonstrating a self-sufficiency that sets them apart. While relatively small and remote, Saint Pierre and Miquelon’s legal system boasts a flexibility and independence that many legal scholars might find intriguing.
Garon, Nicolas, The Hidden, True Civil Law Jurisdiction in North America and Factors of Distance (September 27, 2023).
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