Public Prosecutors in the United States and Europe

A Comparative Analysis with Special Focus on Switzerland, France, and Germany

Nonfiction, Reference & Language, Law, International, Social & Cultural Studies, Social Science, Crimes & Criminals, Criminology
Cover of the book Public Prosecutors in the United States and Europe by Gwladys Gilliéron, Springer International Publishing
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Author: Gwladys Gilliéron ISBN: 9783319045047
Publisher: Springer International Publishing Publication: April 14, 2014
Imprint: Springer Language: English
Author: Gwladys Gilliéron
ISBN: 9783319045047
Publisher: Springer International Publishing
Publication: April 14, 2014
Imprint: Springer
Language: English

This research examines the role of prosecutors within the United States and in Switzerland and is completed by an overview of the prosecution institutions in France and Germany. The research recognizes that despite seemingly very different legal traditions and structures, prosecutors in these systems are similar enough that each system might learn from the others. Drawing upon the experiences of other nations, this research proposes solutions to the problems identified in connection with the position and powers of public prosecutors in the United States. Furthermore, it outlines the problems related to the increase of prosecutorial power and the lessons the European criminal justice systems surveyed can draw from the experience in the US. In terms of methodology, this research not only considers formal legal provisions but also systematic structural factors, academic literature and statistics revealing how the law and governing principles actually work in practice.

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This research examines the role of prosecutors within the United States and in Switzerland and is completed by an overview of the prosecution institutions in France and Germany. The research recognizes that despite seemingly very different legal traditions and structures, prosecutors in these systems are similar enough that each system might learn from the others. Drawing upon the experiences of other nations, this research proposes solutions to the problems identified in connection with the position and powers of public prosecutors in the United States. Furthermore, it outlines the problems related to the increase of prosecutorial power and the lessons the European criminal justice systems surveyed can draw from the experience in the US. In terms of methodology, this research not only considers formal legal provisions but also systematic structural factors, academic literature and statistics revealing how the law and governing principles actually work in practice.

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