Law Comparative Law European Union Law

Public Prosecutors in the United States and Europe: A Comparative Analysis with Special Focus on Switzerland, France, and Germany

By Gwladys Gillieron
Springer-Verlag April 2014

Specifications

ISBN-13
9783319045030
Publisher
Springer-Verlag
Publication
April 2014
Format
Hardback
Jurisdiction
Switzerland ? Countri(es) for reference only

Details

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.

Table of Contents

Aim, Approach, and Methodology of the Study
Methods for Coping with Overloaded Criminal Justice Systems
The Criminal Justice Systems Studied
History of the Public Prosecutor
Public Prosecutors in the United States: Position, Powers, and Accountability
Public Prosecutors in Switzerland: Position, Powers, and Accountability
Overview of Public Prosecutors in Germany: Position, Powers, and Accountability
Overview of Public Prosecutors in France: Position, Powers, and Accountability
Comparative Overview of Position, Powers, and Accountability of Public Prosecutors
Thematic Problems and the Prospects for Reform
Conclusion.
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