4 ms·

Even England Scotland and Wales are separate countries. I suppose in theory the US already has a mechanism for managing this disagreement federal and state law

Even England Scotland and Wales are separate countries. I suppose in theory the US already has a mechanism for managing this disagreement federal and state laws.

ElfinTrousers 4y ago
I'm not an expert in UK law but I'm pretty sure that the variation in laws between one US state and another are much bigger than the variation between the four constituent UK countries.
- matthewmacleod 4y ago
  There's actually quite a substantial difference between Scots law versus English and Welsh law in particular! Even disregarding substantial divergence in legislation, Scots law is a mixed civil/common law system, versus the common law system of England and Wales. I'm no US legal expert, but I'd imagine the differences are roughly on par to those found between US states. My understanding is that it's similar to the sort of difference you'd see between Louisiana's system and other states'.
  - ElfinTrousers 4y ago
    TIL. I'd ask now what the difference is between a barrister and a solicitor, but I'm not sure that's a thing an American is even capable of understanding.
    - matthewmacleod 4y ago
      At the simplest level it’s really just the lawyers who operate in the court (barristers) versus those who operate outwith it (solicitors). It’s a bit more complex and couched in tradition but that’s the gist of it. It’s actually from the same etymology as the “Bar” in the US, as in “admission to the bar” or “the bar association”. It represents a person who has “passed the bar” in the courtroom, separating spectators from participants. It’s just that the setup is a little different, with most solicitors not having a right of audience in the court. Another difference in Scots law - no barristers but “advocates” instead.
      - ElfinTrousers 4y ago
        Thanks, very interesting.
- psychphysic 4y ago
  That was sort of my point. The idea is that Europe is much more varied than the US. Yet the UK is a country seemingly made up of countries. So difference isn't enough? And the US already has a system to allow quite different laws to be enacted.
  - ElfinTrousers 4y ago
    Ah, I misunderstood. The thing is, although I believe the US government is more decentralized than your typical European government, and you're right that the various states have very different laws, the Federal government is still extremely powerful, and Federal law covers every subject that you can think of. Since the spectrum of political opinion represented is so wide, this means that any decision the Federal government makes will upset a lot of people. There basically never is a compromise decision that everyone feels at least OK about.

Even England Scotland and Wales are separate countries. I suppose in theory the US already has a mechanism for managing this disagreement federal and state laws.

ElfinTrousers 4y ago

I'm not an expert in UK law but I'm pretty sure that the variation in laws between one US state and another are much bigger than the variation between the four constituent UK countries.

matthewmacleod 4y ago
There's actually quite a substantial difference between Scots law versus English and Welsh law in particular! Even disregarding substantial divergence in legislation, Scots law is a mixed civil/common law system, versus the common law system of England and Wales. I'm no US legal expert, but I'd imagine the differences are roughly on par to those found between US states. My understanding is that it's similar to the sort of difference you'd see between Louisiana's system and other states'.
- ElfinTrousers 4y ago
  TIL. I'd ask now what the difference is between a barrister and a solicitor, but I'm not sure that's a thing an American is even capable of understanding.
  - matthewmacleod 4y ago
    At the simplest level it’s really just the lawyers who operate in the court (barristers) versus those who operate outwith it (solicitors). It’s a bit more complex and couched in tradition but that’s the gist of it. It’s actually from the same etymology as the “Bar” in the US, as in “admission to the bar” or “the bar association”. It represents a person who has “passed the bar” in the courtroom, separating spectators from participants. It’s just that the setup is a little different, with most solicitors not having a right of audience in the court. Another difference in Scots law - no barristers but “advocates” instead.
    - ElfinTrousers 4y ago
      Thanks, very interesting.
psychphysic 4y ago
That was sort of my point. The idea is that Europe is much more varied than the US. Yet the UK is a country seemingly made up of countries. So difference isn't enough? And the US already has a system to allow quite different laws to be enacted.
- ElfinTrousers 4y ago
  Ah, I misunderstood. The thing is, although I believe the US government is more decentralized than your typical European government, and you're right that the various states have very different laws, the Federal government is still extremely powerful, and Federal law covers every subject that you can think of. Since the spectrum of political opinion represented is so wide, this means that any decision the Federal government makes will upset a lot of people. There basically never is a compromise decision that everyone feels at least OK about.