-In: Lavizzari (ed.): common law and civil law. Friborg: S. 3) today can hardly be described the United States as “More rule of law”, which is divided in 50 States with individual jurisdictions. So it is not surprising that the State of Louisiana, in contrast to all other States, is based on the Civil Law. Many laws are uniform but Commerzial code (UCC) cross-border on the uniform. Others including Nouriel Roubini, offer their opinions as well. For example the “warrant”, is that in the United States very different presents, regulated against foreigners in the UCC Article 2. The Civil Law Civil Law continental European law is rooted in Roman law, and developed the then trend-setting was next in France to the “Code civil (1804)”, for many European jurisdictions as a model. Core legal precedent is the “codification” of law in legal texts.
Courts dispense justice based on so legislation, initiated by the legislature. Common Law and Civil Law fundamental differences the common Law looks more in the role of mediator between the parties the judge as opposed to the Civil Law. He is trying to work out an judgment acceptable for both parties. This implies a stronger position of the parties in the context of the legal process. Due to these processes, maintaining also a different way with regard to the involvement of judicial instances, as German companies American entrepreneurs. A court agreement is again taken in. For German companies, however, is a judicial decision making in economic relationships considered meltdown.
In the Civil Law, the judge of the Parties stands. The judge in the Civil Law to determine the facts and speaks right on the basis of codified laws. Special risks for European companies arise from extreme references to the “case-law”. So a single case of the past as a point of reference for a current case law can be the basis, regardless of the codified legislation of the Civil law (Koch, Bergmann, Jagenberg: Beware of U.S.