Although criminals are treated more or less the same in all three countries, and in most cases can expect a similar punishment, their systems of justice are based on principles that are often profoundly different. Below are some of the key differences.
Some that consists of many of the same policies and some that are considerably different. In the case of France and the U. The aspects that I will be comparing are police, courts, the legal profession, legal education, criminal procedural law, corrections, and juvenile justice and the advantages and disadvantages of each.
The policing system in France is a lot different than the one in the U. In France there is one big centralized police system run by the government.
Unlike the fragmented police model, which is found in the United States and is attributed to the federated nature of the political system, the centralized police system is imposed on the people by the national government. In France, the emphasis has been on establishing police forces is administered, supervised, and coordinated by the national government Terrill This is a major advantage because there are most likely the same laws throughout the country.
Another difference in policing is the entry system. Today 83 percent of all local police departments require at least a high school diploma, and 8 percent require a degree from a two year college Gaines and Miller France however, has a four tiered entry scheme which focuses on the university graduate.
You must first become a patrol officer, but only with a degree and plenty of schooling and training, you can move up to a plainclothes officer, which are the equivalent of a lieutenant or chief of police. From their perspective, the multilevel entrance scheme enables the police to tap the creative resources of the university graduate Terrill The disadvantage of this is that many patrol officers with no degree could be just as know ledged and trained as a plainclothes officer, but not be able to move up in the rankings as fast as someone with a degree.
Another difference between the two countries is their court system. France does not practice judicial review. In the United States, the Supreme Court has the principle responsibility of ruling on the constitutionality of all laws.
This kind of judicial review is not practiced in France Terrill In France they have the Constitutional council which has nine members serving a nine year term, they are responsible for election complaints and the legislation made in parliament.
The advantage of this is that it reduces the conflict of jurisdictions. But the disadvantage is that our Supreme Court has a longer term than the Constitutional Council which allows more constant laws and fewer laws that will contradict each other.
The aspect of legal profession and legal education is also extremely different. To become a judge in France you must first obtain a law degree from a university law school.
After completing this school, the candidate is now qualified to become a judge. The French system allows judges to begin their profession at an early age which could be a disadvantage because of lack of experience in the system, where judges in the United States are usually older and more knowledgeable.United Kingdom; See All Locations» "A comparison of England's criminal court system with the United States" Last year I had the opportunity .
Criminal Justice in London Comparing and Contrasting the criminal justice systems of the UK and the US.
Menu. Introduction; Introduction. In May , we set off to London to explore various aspects of the English criminal justice system. Our group consists of both graduate and undergraduate students from Weber State University located in.
Major Differences Between the US and UK Legal Systems. April 07, by Piyali Syam Attorneys probably already know legal systems in both the U.K.
and the U.S. share the same historical common law roots, and are for that reason quite similar. North Carolina Criminal Law NC Criminal Law.
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Subscribe. About. Home; there were moments when the two systems seemed fundamentally alike. For example, one prosecutor contended that Mexico was unique in that Mexican prosecutors carried large caseloads, dealt with officers whose reports .
The volume begins with an analysis of the nature of comparative and international criminal justice, with emphasis on the reasons for studying comparative criminal justice systems given the reality of differences in customs, traditions, standards, values, and criminal law across cultures.
The two criminal justice systems that shall be discussed in this paper are those of the United States and that of the People’s Republic of China.
When comparing and contrasting these two systems one should start with the premise that both are instituted in their countries in the attempt to curb.