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University of Michigan Law School

1984

Comparative and Foreign Law

United States

Articles 1 - 6 of 6

Full-Text Articles in Law

The Supervision Of Corporate Management: A Comparison Of Developments In European Community And United States Law, Alfred F. Conard May 1984

The Supervision Of Corporate Management: A Comparison Of Developments In European Community And United States Law, Alfred F. Conard

Michigan Law Review

In 1971, Eric Stein published an account of the remarkable progress of the European Economic Community (EEC) toward a harmonized law of business corporations. The progress was particularly striking from an American viewpoint, because the harmonization was achieved by moving toward the more rigorous of the various national standards, in contrast to the "race of laxity" or "race for the bottom" that has characterized the movement toward uniformity in the corporation laws of U.S. states.


Judicial Jurisdiction In The United States And In The European Communities: A Comparison, Friedrich Juenger May 1984

Judicial Jurisdiction In The United States And In The European Communities: A Comparison, Friedrich Juenger

Michigan Law Review

Eric Stein deserves our gratitude for making European integration accessible to American students and teachers. He has taught and written widely on this important subject, and the casebook he published with Hay and Waelbroeck is a valuable aid for dispelling what a judge of the Communities' Court of Justice called "splendid mutual ignorance." Following Judge Pescatore's suggestion that it is time to take note of the experience gathered on both sides of the Atlantic, it seems worthwhile to compare the evolution of jurisdictional principles in the United States and in the Common Market.


Tightening The Reins Of Justice In America: A Comparative Analysis Of The Criminal Jury I England And The United States, Michigan Law Review Feb 1984

Tightening The Reins Of Justice In America: A Comparative Analysis Of The Criminal Jury I England And The United States, Michigan Law Review

Michigan Law Review

A Review of Tightening the Reins of Justice in America: A Comparative Analysis of the Criminal Jury I England and the United States by Michael H. Graham


Political Asylum In The Federal Republic Of Germany And The Republic Of France: Lessons For The United States, T. Alexander Aleinikoff Jan 1984

Political Asylum In The Federal Republic Of Germany And The Republic Of France: Lessons For The United States, T. Alexander Aleinikoff

University of Michigan Journal of Law Reform

The recent flood of asylum claims, and the concerns it engenders, are not peculiar to the United States. Western European nations have witnessed similar increases in asylum applications over the past decade, .and institutions charged with adjudicating claims have become severely overburdened. This Article will describe the experience of the Federal Republic of Germany and the Republic of France in coping with the explosion of asylum claims. A comparative analysis may provide perspective on the American situation and perhaps suggest - or rule out - proposals for change currently under consideration in the United States. To appreciate the saliency of …


The Large Civil Aircraft Industry: Applying Legal Policy-Making Tools To Accommodate A Changing Industry, Dennis G. Terez Jan 1984

The Large Civil Aircraft Industry: Applying Legal Policy-Making Tools To Accommodate A Changing Industry, Dennis G. Terez

Michigan Journal of International Law

This note first examines the emergence of Airbus Industrie (Al or Airbus) and identifies some of the legal and policy instruments which the European governments have employed to make Al a successful competitor. After a brief discussion of the growing difficulties with subsidy policies, the note considers European Community legislation for a common European industrial policy and the creation of a European Export Bank as possible alternative solutions for maintaining Al's competitiveness. The note finally argues that international industrial agreements are necessary legal tools for effective regulation of the manufacture and sale of large civil aircraft. International agreements currently in …


The Role Of The Federal Government In Worker Adjustment Assistance, Linda Elliott Jan 1984

The Role Of The Federal Government In Worker Adjustment Assistance, Linda Elliott

Michigan Journal of International Law

Part I of this note examines worker adjustment assistance in the United States. It traces TAA's evolution from its inception as a means of compensating trade-displaced workers while minimizing government intervention in the market adjustment process, through its amendment to reflect congressional concern over the low number of worker certifications, to the criticism of its procedures arising out of more recent congressional interest in government-sponsored retraining as a means of attaining worker adjustment. After arguing that current certification and distribution procedures continue to reflect the original goal of the program- compensation with minimal intervention in the market- the note examines …