in the united states, louisiana attorney samuel livermore (who wrote the first american treatise of conflict of laws in 1828) expressly rejected the comity doctrine as formulated by mansfield and earlier writers, instead arguing that "courts were bound by international law to apply the same law that a foreign court would apply." this idea was rejected by justice joseph story of the supreme court, who agreed with mansfield and huber in his "commentaries on the conflict of laws". story's view, which ultimately prevailed, was that the consensual or voluntary application of comity doctrine would foster trust among states, "localize the effect of slavery," and reduce the risk of civil war.