Abstract

This paper explores the issues of judicial dialogue and constitutional migrations between the European Court of Justice (‘ECJ’) and Latin American regional courts. It considers the impact of the ECJ’s ‘constitutional’ case-law regarding supremacy and direct effect on the decisions of the Central American Court of Justice (‘CCJ’) and the Court of Justice of the Andean Community (‘ACCJ’). The study proceeds from a brief exposition of the legal aspects of the EU model of integration, before moving to identify the main factors which led to the selection of Latin American courts and to outline the background to integration in the two sub-regions. In addressing the CCJ and ACCJ, a short history and sketch of their jurisdiction is given before examining the impact of the migration of the integrationist activism of the ECJ on these regional judicial institutions.