Keywords
English Legal Terminology, Civil Law, Comparative Law, CIVLET, COMLET, COMPLET, Louisiana Civil Code, Civil Code of Québec
Abstract
In the early 19th century, Louisiana codified its civil law in French and in English. In the 20th century, it translated French civilian doctrine and then produced its own civilian literature in English. Over time, lawmakers and translators have crafted and refined new English legal terminology suited to expressing civilian concepts, thereby setting aside common law terminology. Quebec joined the process once Canada imposed bilingualism, while other English-speaking mixed jurisdictions also contributed. This article shows how, outside the common law English terminology (COMLET), a civil law English terminology (CIVLET) is developing, and is also enriched by a comparative law English terminology (COMPLET).
While COMPLET is needed to produce uniform laws and comparative law scholarship, the CIVLET should prevail regarding the production and translation of civil law concepts. Using the CIVLET may strengthen the civil law tradition at a time when the prevalent use of the COMLET on the international stage threatens the integrity of the civil law tradition.
Repository Citation
Olivier Moreteau,
The Civil Law English Terminology (CIVLET), A Louisiana Gift to the World,
18 J. Civ. L. Stud.
(2026)
Available at: https://digitalcommons.law.lsu.edu/jcls/vol18/iss1/6