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Public Prosecutors in the United States and Europe - A Comparative Analysis with Special Focus on Switzerland, France, and Germany (Hardcover, 2014 ed.)
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Public Prosecutors in the United States and Europe - A Comparative Analysis with Special Focus on Switzerland, France, and Germany (Hardcover, 2014 ed.)
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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.
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