Arno

This appeal raises an unusual conflict of law issue. Appellant Carolyn Arno’s supervisor sexually assaulted her while she was working at a Club Med resort in Guadeloupe, which is governed by French law. In Arno’s first appeal, we decided that French law, as *1425 the law'of the place where the tort occurred,, rather than the law of California, the forum state and residence of the plaintiff, governed the substance of her tort action. Arno v. Club Med, Inc., 22 F.3d 1464, 1468 (9th Cir.1994). The parties subsequently settled the substantive issues of the case, reserving the question of fees. The issue before us is-whether California or French law applies to the fee issue. Applying California’s substantive choice of law analysis, the district court determined that California law governed because neither jurisdiction had an interest in. applying its law, and therefore the law of thp forum applied. It denied Arno’s application for fees. We affirm on somewhat different grounds.

It is undisputed that the law of California and the law of France differ as to' the availability of attorneys’ fees. California applies the “American Rule,” under which each party must bear its own fee…