5 ms·

>The UK has a lot more in common politically and philosophically with the US than the EU. Not even close, let's take a basic fundamental US principle like the

>The UK has a lot more in common politically and philosophically with the US than the EU. Not even close, let's take a basic fundamental US principle like the right to free speech, it doesn't exist in the UK. The UK has had relation ships with most of the European countries for longer than the US has existed. The UK has more import and exports with the EU that the US and because of geographic constraints this will not change Brexit or not.

gadders 7y ago
>>Not even close, let's take a basic fundamental US principle like the right to free speech, it doesn't exist in the UK. Sadly, this is correct, but I believe the UK has less constrained speech than continental Europe. I'd love to see a right to free speech brought into force in the UK >>The UK has had relation ships with most of the European countries for longer than the US has existed. This is also true, but neglects the fact that US was founded by Britain and was a British colony for 170 years. US law is based on English common law.
gnode 7y ago
> US principle like the right to free speech, it doesn't exist in the UK. The UK has a right to freedom of expression in both common law and the Human Rights Act (incorporation of the European Convention on Human Rights). There are many exceptions, but that's also the case for the First Amendment of the United States' constitution. Both the UK and US have defamation laws, criminalise real threats, Official Secrets Act / Espionage Act, gag orders, etc. One could argue there is a better right to free speech in the US, and that it has stronger legal protections, but it's by no means absolute or beyond comparison with that of the UK.
- dangerface 7y ago
  > One could argue there is a better right to free speech in the US, and that it has stronger legal protections, but it's by no means absolute or beyond comparison with that of the UK. Yes in the UK freedom of speech and religion is tolerated to an extent that exceeds the word of the very restrictive law, but the US has actual legal protections and a culture that protects those legal protections, there is a very big difference between the two. You can compare the US free speech with our limited speech but at the end of the day Spain has free speech and privacy laws and culture thats way closer to the US than the UK nanny state. There are other big differences between US and UK culture like GUNS! to name one The only thing the UK and US hold in common is the want to have an empire. Oh and to steal brown people oil.
rleigh 7y ago
> Not even close. It's actually bang on the money. Two words: Common Law. I would suggest, strongly, that the UK does indeed have vastly more in common with the US, at the most fundamental level. Our freedoms, law, government and society at large are based upon it, and this makes our countries much closer than any European nation based upon Civil Law will ever be. It's not just down to legalities, it shapes our entire attitude to how a society should run, and how the laws of the land are made and changed over time. In all these things, the UK and US are almost entirely the same. Common Law is central to the fundamental philosophy, and political and judicial processes which make our societies run. Most European countries have Civil Law. It's very different, and I would argue that much of the friction between EU institutions and UK law (and public) is because it's trying to impose the Civil Law framework onto a Common Law system, and it's not really compatible. Much of the time, in the UK, we look at the actions and attitudes of EU political figures with disbelief. Because they make little sense, for people used to Common Law. In Civil Law, it's more understandable. The public's expectations are quite different in both systems, and this is a fundamental disconnect which can't be papered over. It's one of the reason many in the UK, including myself, feel that the rules-based EU is fundamentally undemocratic and unfit for purpose. Because from our rather less hidebound and laissez-faire point of view, this is absolutely the case. We're much more used to the "whatever is not specifically forbidden, is allowed" point of view. And when it comes to the law, we're used to our juries and judges being able to interpret and shape the law in new ways by common sense, rather than being rigidly stuck to the letter.

gadders 7y ago

>>Not even close, let's take a basic fundamental US principle like the right to free speech, it doesn't exist in the UK. Sadly, this is correct, but I believe the UK has less constrained speech than continental Europe. I'd love to see a right to free speech brought into force in the UK >>The UK has had relation ships with most of the European countries for longer than the US has existed. This is also true, but neglects the fact that US was founded by Britain and was a British colony for 170 years. US law is based on English common law.

gnode 7y ago

> US principle like the right to free speech, it doesn't exist in the UK. The UK has a right to freedom of expression in both common law and the Human Rights Act (incorporation of the European Convention on Human Rights). There are many exceptions, but that's also the case for the First Amendment of the United States' constitution. Both the UK and US have defamation laws, criminalise real threats, Official Secrets Act / Espionage Act, gag orders, etc. One could argue there is a better right to free speech in the US, and that it has stronger legal protections, but it's by no means absolute or beyond comparison with that of the UK.

dangerface 7y ago
> One could argue there is a better right to free speech in the US, and that it has stronger legal protections, but it's by no means absolute or beyond comparison with that of the UK. Yes in the UK freedom of speech and religion is tolerated to an extent that exceeds the word of the very restrictive law, but the US has actual legal protections and a culture that protects those legal protections, there is a very big difference between the two. You can compare the US free speech with our limited speech but at the end of the day Spain has free speech and privacy laws and culture thats way closer to the US than the UK nanny state. There are other big differences between US and UK culture like GUNS! to name one The only thing the UK and US hold in common is the want to have an empire. Oh and to steal brown people oil.

rleigh 7y ago

> Not even close. It's actually bang on the money. Two words: Common Law. I would suggest, strongly, that the UK does indeed have vastly more in common with the US, at the most fundamental level. Our freedoms, law, government and society at large are based upon it, and this makes our countries much closer than any European nation based upon Civil Law will ever be. It's not just down to legalities, it shapes our entire attitude to how a society should run, and how the laws of the land are made and changed over time. In all these things, the UK and US are almost entirely the same. Common Law is central to the fundamental philosophy, and political and judicial processes which make our societies run. Most European countries have Civil Law. It's very different, and I would argue that much of the friction between EU institutions and UK law (and public) is because it's trying to impose the Civil Law framework onto a Common Law system, and it's not really compatible. Much of the time, in the UK, we look at the actions and attitudes of EU political figures with disbelief. Because they make little sense, for people used to Common Law. In Civil Law, it's more understandable. The public's expectations are quite different in both systems, and this is a fundamental disconnect which can't be papered over. It's one of the reason many in the UK, including myself, feel that the rules-based EU is fundamentally undemocratic and unfit for purpose. Because from our rather less hidebound and laissez-faire point of view, this is absolutely the case. We're much more used to the "whatever is not specifically forbidden, is allowed" point of view. And when it comes to the law, we're used to our juries and judges being able to interpret and shape the law in new ways by common sense, rather than being rigidly stuck to the letter.