I like the Spanish mechanism: Loser pays is possible, but it is definitely not the rule. For the loser to have to pay costs, you have to show that the suit was

I like the Spanish mechanism: Loser pays is possible, but it is definitely not the rule. For the loser to have to pay costs, you have to show that the suit was filed in bad faith, typically with a completely baseless claim. This occurs a good enough percentage of the time to deter people from suing at random, but it's not in any way guaranteed to happen every time you lose: There are plenty of civil suits are there where both sides have legitimate arguments, and where everyone eats their own expenses. There's also rules about what reasonable legal costs are, to deter major bill padding.