A different kind of foreign law in American courts

"Henry Helm was interdicted … He argues that by virtue of his appointment of his niece Barbara Manteris as his procuratrix she … was entitled to preference in the appointment of a curatrix…. Because we find that [Donna Oufnac's] duties as undercuratrix are in irremediable conflict with her obligations as surety to the curatrix, we reverse the judgment in part and vacate her appointment as a co-undercurator."

Chez what? I can handle "voir dire" and even Alien Amy, but this is too much ….