2 ms·
You’ve got it backwards. The US allows for a lot of interpretation on intent and context by judges. In the EU this is far more restricted and the black letter
by turquoisevar 3y ago
You’ve got it backwards.
The US allows for a lot of interpretation on intent and context by judges. In the EU this is far more restricted and the black letter law is way more important.
That said, in the EU there’s more of a tradition in civil law cases to deviate from the law and agreements for “the sake of equity” (i.e., civil law judges love to split the baby and have everyone be a little unhappy).
This is of course not civil law but administrative law, which in the US isn’t really a thing. In the US non-criminal cases involving the government are adjudicated according to civil law v (for the most part).
Source: before getting into software engineering I practiced law in the EU, during my last years in law school I focused on comparative law, now living in the US and married to a lawyer who went to law school in the US
Or you know, just trust me bro, because I’m just a stranger in the internet.