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Comparative Law

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Articles 121 - 150 of 193

Full-Text Articles in Comparative and Foreign Law

The Advantages Of The Civil Law Judiciary As The Model For Emerging Legal Systems, Charles H. Koch Jr. Jan 2004

The Advantages Of The Civil Law Judiciary As The Model For Emerging Legal Systems, Charles H. Koch Jr.

Faculty Publications

No abstract provided.


Comparative Reasoning And Judicial Review, Sarah K. Harding Feb 2003

Comparative Reasoning And Judicial Review, Sarah K. Harding

All Faculty Scholarship

No abstract provided.


Responding To Terrorism: How Must A Democracy Do It? A Comparison Of Israeli And American Law, Jonathan Grebinar Jan 2003

Responding To Terrorism: How Must A Democracy Do It? A Comparison Of Israeli And American Law, Jonathan Grebinar

Fordham Urban Law Journal

This Comment compares the Israeli and American laws that sanction controversial responses to terrorism. It discusses criticisms of these laws with respect to human rights violations and how, if at all, the two governments strive to preserve their law's effectiveness without violating international standards. Part I of this comment briefly discusses the origins of terrorism and establishes a universal definition for the word. Part II reviews the history of three Israeli responses to terrorism, including 1) administrative detention, 2) torture, and 3) the demolition of houses; and describes how these tactics are criticized domestically as well as internationally. Part II …


Two Sides Of A "Sargasso Sea": Successive Prosecution For The "Same Offence" In The United States And The United Kingdom, Lissa Griffin Jan 2003

Two Sides Of A "Sargasso Sea": Successive Prosecution For The "Same Offence" In The United States And The United Kingdom, Lissa Griffin

Elisabeth Haub School of Law Faculty Publications

This article analyzes the U. S. constitutional law interpreting the concept of “same offence.” Included is a survey of the Supreme Court's attempts to interpret constitutional text in order to provide adequate protection for the underlying double jeopardy interest against vexatious reprosecutions, which have frequently produced inconsistent and illogical results. Part III of this article analyzes U.K. law relating to the concept of “same offence,” where the same narrow double jeopardy protection adopted by the U.S. Supreme Court is supplemented with a broad discretion to prevent unfair successive prosecution that constitutes an abuse of process. Part IV draws lessons from …


Ending Marriage As We Know It, Nancy Polikoff Jan 2003

Ending Marriage As We Know It, Nancy Polikoff

Scholarly Articles in Law Reviews & Journals

No abstract provided.


Restoring Faith In Government: Transparency Reform In The United States And The European Union, Amanda Frost Jan 2003

Restoring Faith In Government: Transparency Reform In The United States And The European Union, Amanda Frost

Scholarly Articles in Law Reviews & Journals

No abstract provided.


Hans Kelsen And The Logic Of Legal Systems, Michael S. Green Jan 2003

Hans Kelsen And The Logic Of Legal Systems, Michael S. Green

Faculty Publications

No abstract provided.


Comparing Procedural Systems: Toward An Analytical Framework, David J. Gerber Jan 2002

Comparing Procedural Systems: Toward An Analytical Framework, David J. Gerber

All Faculty Scholarship

No abstract provided.


Super Regulator: A Comparative Analysis Of Securities And Derivatives Regulation In The United States, The United Kingdom, And Japan, Jerry W. Markham Jan 2002

Super Regulator: A Comparative Analysis Of Securities And Derivatives Regulation In The United States, The United Kingdom, And Japan, Jerry W. Markham

Faculty Publications

This article describes the development of the competing regulatory bodies for banking, insurance, securities and derivatives. It then focuses on the regulatory roles of the Securities and Exchange Commission ("SEC") and the Commodity Futures Trading Commission ("CFTC"). The competition between those two agencies and its effects are described. After that review, the article examines the roles of the FSA-GB and FSA-Japan. Finally, the article discusses the arguments favoring and disfavoring competitive regulation and tries to discern whether a unified regulatory structure such as that in Japan and England is preferable to the competitive approach of the SEC and CFTC. The …


Federalism, Democratization, And The Rule Of Law In Russia, Jeffrey D. Kahn Jan 2002

Federalism, Democratization, And The Rule Of Law In Russia, Jeffrey D. Kahn

Faculty Journal Articles and Book Chapters

Combining the approaches of three fields of scholarship - political science, law and Russian area studies - the author of this 2002 Oxford University Press book explores the foundations and future of the Russian Federation. Russia's political elite have struggled to build an extraordinarily complex federal system, one that incorporates eighty-nine different units and scores of different ethnic groups, which sometimes harbor long histories of resentment against Russian imperial and Soviet legacies. This book examines the public debates, official documents and political deals that built Russia's federal house on very unsteady foundations, often out of the ideological, conceptual and physical …


Strengthening Access To Information And Public Participation In Transition Countries - Latvia As A Case Study In Administrative Law Reform, Jeffrey Lubbers Jan 2002

Strengthening Access To Information And Public Participation In Transition Countries - Latvia As A Case Study In Administrative Law Reform, Jeffrey Lubbers

Scholarly Articles in Law Reviews & Journals

No abstract provided.


Globalization And Legal Knowledge: Implications For Comparative Law, David J. Gerber Jan 2001

Globalization And Legal Knowledge: Implications For Comparative Law, David J. Gerber

All Faculty Scholarship

No abstract provided.


Sculpting The Agenda Of Comparative Law: Ernst Rabel And The Façade Of Language, David J. Gerber Jan 2001

Sculpting The Agenda Of Comparative Law: Ernst Rabel And The Façade Of Language, David J. Gerber

All Faculty Scholarship

No abstract provided.


The Correction Of Wrongful Convictions: A Comparative Perspective, Lissa Griffin Jan 2001

The Correction Of Wrongful Convictions: A Comparative Perspective, Lissa Griffin

Elisabeth Haub School of Law Faculty Publications

This Article analyzes the different modes in which two facially similar adversarial systems remedy wrongful convictions. Part I briefly examines the origins of wrongful convictions in both England and the United States. Part II describes the appellate processes in the two countries for correcting wrongful convictions. Part III addresses the processes for correcting wrongful convictions after the appellate processes have been completed. Part IV critiques the English process and examines whether aspects of that process may be carried over to the United States.


Lawyers Without Frontiers - A View From Germany, Martin Henssler, Laurel S. Terry Jan 2001

Lawyers Without Frontiers - A View From Germany, Martin Henssler, Laurel S. Terry

Faculty Scholarly Works

This article addresses the effect in Germany of the globalization of legal services. The first section of the article consists of reflections about the development of the German legal market in the past decade and how this development has been influenced by Anglo-Saxon law firms from the U.S. and England. The second section of this paper provides a more detailed analysis of the legal framework that governs the practice of foreign lawyers in Germany will follow. The third section of this paper addresses the issue of Multi-Disciplinary-Practices between lawyers and accountants. These MDPs are forbidden almost everywhere in the world …


Comparative Law As A Comprehensive Approach: A European Tribute To Professor Jack A. Hiller, Bernhard Grossfield Jan 2000

Comparative Law As A Comprehensive Approach: A European Tribute To Professor Jack A. Hiller, Bernhard Grossfield

Richmond Journal of Global Law & Business

An aura of "malaise" hangs over the field of Comparative Law'- sometimes alluded to as the "drama" of Comparative Law (private and public). Indeed, the comparative scholar is often asked whether his work has any practical importance. This is the question he fears most. A German legal philosopher once criticized the whole approach as follows: "Nobody asks what comparative law is and how it should be pursued. Thus, it is less to build a new structure from the laws compared, but to leave an accumulation of raw bricks in a heap that will never be used." Still today it is …


Fox Hunting, Pheasant Shooting And Comparative Law, Alan Watson, Khaled Abou El Fadl Jan 2000

Fox Hunting, Pheasant Shooting And Comparative Law, Alan Watson, Khaled Abou El Fadl

Scholarly Works

The Roman jurists, ancient rabbis and Muslim jurists were very different people. Above all, the rabbis and Muslim jurists were engaged on a search for law as truth. And the Roman jurists were much more obviously upper-class gentlemen.91 But the similarities are great. All three had a passion for legal interpretation. They delighted in discussing hypothetical cases. They chased after solutions by ways of reasoning devised by themselves. Practical utility, while present, was in the background. At times, to outsiders, their opinions seem outr6, even callous, remote from reality. They have little interest in what actually happens in court: their …


System Dynamics: Toward A Language Of Comparative Law, David J. Gerber Jan 1998

System Dynamics: Toward A Language Of Comparative Law, David J. Gerber

All Faculty Scholarship

No abstract provided.


Comparative Environmental Law Perspectives On Legal Regimes For Sustainable Development, Nicholas A. Robinson Jan 1998

Comparative Environmental Law Perspectives On Legal Regimes For Sustainable Development, Nicholas A. Robinson

Elisabeth Haub School of Law Faculty Publications

As the world's largest summit meeting ended in Rio de Janeiro in 1992, the heads of state and their representatives assembled at the United Nations Conference on Environment and Development (UNCED), commonly referred to as Agenda 21. They embraced Agenda 21 as “a dynamic programme” which can “evolve over time in the light of changing needs and circumstances,” and as a process making “the beginning of a new global partnership for sustainable development.” Agenda 21 is premised on two factual perspectives. First, the documentation of trends in the deterioration of the environmental conditions in many parts of the world is …


Capital Punishment In Jewish Law And Its Application To The American Legal System: A Conceptual Overview, Samuel J. Levine Jan 1997

Capital Punishment In Jewish Law And Its Application To The American Legal System: A Conceptual Overview, Samuel J. Levine

Scholarly Works

In recent years, a growing body of scholarship has developed in the United States that applies concepts in Jewish law to unsettled, controversial, and challenging areas of American legal thought. One area of Jewish legal thought that has found prominence in both American court opinions and American legal scholarship concerns the approach taken by Jewish law to capital punishment. In this Essay, Levine discusses the issue of the death penalty in Jewish law as it relates to the question of the death penalty in American law, a discussion that requires the rejection of simplistic conclusions and the confrontation of the …


Accountability For Past Abuses, Juan E. Mendez Jan 1997

Accountability For Past Abuses, Juan E. Mendez

Scholarly Articles in Law Reviews & Journals

No abstract provided.


Aspects Of Reception Of Law, Alan Watson Apr 1996

Aspects Of Reception Of Law, Alan Watson

Scholarly Works

In most places at most times borrowing is the most fruitful source of legal change. The borrowing may be from within the system, by analogy - from negligence in torts to negligence in contract, for instance - or from another legal system. The act of borrowing is usually simple. To build up a theory of borrowing on the other hand, seems to be an extremely complex matter. Receptions come in all shapes and sizes: from taking over single rules to (theoretically) almost a whole system. They present an array of social phenomena that are not easily explained: from whom can …


The Recognition And Enforcement Of Foreign Equitable Remedies And Other Types Of Non-Money Judgments In United States And French Courts: A Comparative Analysis, Noele Sophie Rigot Jan 1996

The Recognition And Enforcement Of Foreign Equitable Remedies And Other Types Of Non-Money Judgments In United States And French Courts: A Comparative Analysis, Noele Sophie Rigot

LLM Theses and Essays

Courts of industrialized nations are often faced with adjudication of cases which involve foreign components. It is common for those courts to be asked by individuals or legal entities from a transnational environment to adjudicate with regard to some elements already adjudged in a different legal system as if it were a local judgment. The question that arises is how effects should be given when dealing with prior adjudications. Most countries agree to recognize some effects determined by foreign jurisdictions, as long as those determinations meet standards that guarantee proper integration of the foreign decision into the domestic setting. These …


The Evolution Of Free Trade In The Americas: Nafta Case Studies, Claudio Grossman Jan 1996

The Evolution Of Free Trade In The Americas: Nafta Case Studies, Claudio Grossman

Scholarly Articles in Law Reviews & Journals

No abstract provided.


Fusing Economic And Environmental Policy: The Need For Framework Laws In The United States And Argentina, John R. Nolon Jan 1996

Fusing Economic And Environmental Policy: The Need For Framework Laws In The United States And Argentina, John R. Nolon

Elisabeth Haub School of Law Faculty Publications

In an effort to discover the best legal strategies to respond to these new challenges, seminars were conducted among experts in economic development and environmental protection in both the United States and Argentina. The observations and recommendations of these experts have been summarized and published and will be referenced as appropriate. This article attempts to synthesize what was learned in these two seminars, the research conducted in preparation for them, and the ongoing discussion among the participants. It begins with a summary of the forces in both countries that call for a change in the legal system, shows how these …


Choice Of The Applicable Law In United States Maritime Law And The Venezuelan System, Daniel Eric Vielleville Jan 1996

Choice Of The Applicable Law In United States Maritime Law And The Venezuelan System, Daniel Eric Vielleville

LLM Theses and Essays

International maritime transport is an important means of transport in international trade. The vessels used in international maritime transport face unique dangers which necessitate maritime law that addresses the perils associated with maritime transport. Maritime law concerns many jurisdictions, which creates a special interest for the study of conflict of laws. There are private international maritime laws in addition to multilateral treaties. This paper analyzes the international approach that the United States takes in maritime conflict of laws, and compares it with the Venezuelan system of private international law. Venezuela is a civil law country with old maritime legislation which …


Towards A Payments System Law For Developing And Transition Economies, Raj Bhala Sep 1995

Towards A Payments System Law For Developing And Transition Economies, Raj Bhala

Faculty Publications

This paper examines the legal foundations of large-value credit transfer systems and the importance of certainty, efficiency, and fairness in funds transfer law. A case study is presented to highlight key terminology and concepts. Thereafter, five particularly noteworthy legal rules are discussed in the context of the case study: (1) a rule defining the scope of the law; (2) a rule establishing when the rights and obligations of parties to a funds transfer are triggered; (3) a receiver finality rule; (4) a rule assigning liability for interloper fraud; and (5) a money-back guarantee rule, coupled with provisions on discharge. Finally, …


From Legal Transplants To Legal Formats, Alan Watson Jul 1995

From Legal Transplants To Legal Formats, Alan Watson

Scholarly Works

Most of the time rulers and governments in the Western world as a whole were little interested in making private law. Instead, the task devolved upon some group of the legal elite who became in effect subordinate law makers without having been given power to make law. Thus, Roman jurists as such were private individuals with no ties to government: they made law when their opinions came to win approval from other jurists. English judges in the Middle-Ages and later were appointed to decide cases: the tradition long was that they found the law but did not make it. Continental …


The Extraordinary Counter-Majoritarian Power Of The New Supreme Court Of Nepal, Richard Stith Apr 1995

The Extraordinary Counter-Majoritarian Power Of The New Supreme Court Of Nepal, Richard Stith

Law Faculty Publications

No abstract provided.


Bankruptcy In Russia: The Evolution Of A Comprehensive Russian Bankruptcy Code, Paul Williams, Paul Wade Jan 1995

Bankruptcy In Russia: The Evolution Of A Comprehensive Russian Bankruptcy Code, Paul Williams, Paul Wade

Scholarly Articles in Law Reviews & Journals

This article traces the development of the current bankruptcy code, with it origins in the early economic laws of perestroika; explains key provisions of the current law; and comments on the prospects for its effective implementation. The intent of this article is to provide a balanced understanding of the Russian bankruptcy code useful both to the study of the emergence of a market-based economy in Russia and as a bankruptcy primer for individuals or corporations conducting business in Russia.