A Common Law Perspective on the Supreme Court and its Functions

2019, 81, No. 1

University of California, Hastings College of the Law


Publication date

24.10.2019

Publishing model

open access

License type


Field

Law

Discipline

law

Language of publication

English

Downloads

PDF 512 KB

Article

Number of views:228

Number of downloads:60

Crossref citations:0

Altmetric score:0


Abstract

The text presents different attributes of the Supreme Court in common law and civil law systems. The author claims that the question of design and function of a supreme court, while important, is no more significant than the issue of its institutional status and evolution, i.e. something one could refer to as “legal culture”. Neither the “common law camp”, nor the “civil law camp” turns out to be monolithic in this regard. The distinctive history of the US Supreme Court is presented through the perspective of its statutory and procedural supremacy, as well as its power of constitutional adjudication. The author indicates that the supremacy of the US Supreme Court depends on many factors. Arguably, the most important attribute of the US Supreme Court’s supremacy is linked with the latitude offered to judges in common law system to “make law”, which stands in contrast to a limited judicial function in many civil law countries. The author argues that being a court in a common law system carries with it much broader authority. A supreme court in such a system is, as a result, much more supreme. The author concludes his comparative remarks by saying that it is not possible to proclaim the superiority of one specific system because there are too many variables that come into play with regard to respective nations.

Keywords:

Bibliography

Alexander J. C., Do the Merits Matter? A Study of Settlements in Securities Class Actions, 43 “Stanford Law Review” 1991

Andrews N., The United Kingdom’s Supreme Court: Three Skeptical Reflections Concerning the New Court, 9 “Utah Law Review” 2011

Baker T., Griffith S., How the Merits Matter: Directors’ and Officers’ Insurance and Securities Settlements, 157 “University of Pennsylvania Law Review” 2008

Bhagwati P. N., Judicial Activism and Public Interest Litigation, 23 “Columbia Journal of Transnational Law” 1985

Brennan W., The National Court of Appeals: Another Dissent, 40 “University of Chicago Law Review” 1973

Burbank S., The Rules Enabling Act of 1934, 130 “University of Pennsylvania Law Review” 1982

Cappelletti M., Judicial Review in the Contemporary World, 1971

Carrington P., Aponovich D., The Constitutional Limits of Judicial Rulemaking: The Illegitimacy of Mass-Torts Settlements Negotiated Under Rule 23, 39 “Arizona Law Review” 1997

Chayes A., The Role of the Judge in Public Law Litigation, 89 “Harvard Law Review” 1976

Coffee J., Reforming the Securities Class Action: An Essay on Deterrence and Its Implementation, 106 “Columbia Law Review” 2006

Cohen J. C., The European Preliminary Reference and US Supreme Court Review of State Court Judgments: A Study in Comparative Federalism, 44 Am. J. Comp. Law “American Journal of Comparative Law” 1996

Crowe J., Building the Judiciary, 2011

Dalton H., Taking the Right to Appeal (More or Less) Seriously, 95 Yale L.J. “The Yale Law Journal” 1985

Dorf M. C., Abstract and Concrete Review, (in:) V. Amar, M. Tushnet (eds.), Global Perspectives on Constitutional Law, 2009

Fennell M., Emergent Identity. A Comparative Analysis of the New Supreme Court of the United Kingdom and the Supreme Court of the United States, 22 “Temple International and Comparative Law Journal” 2008

Gamper A., Palermo F., The Constitutional Court of Austria: Modern Profiles of an Archetype of Constitutional Review in Comparative Perspective, (in:) A. Harding, P. Leyland (eds.), Constitutional Courts: A Comparative Study, 2009

Harding A., Leyland P., Groppi T., Constitutional Courts: Forms, Functions and Practice in Comparative Perspective, (in:) Harding & Leyland

Harris G., Beijing’s Bad Air Would Be A Step Up for Smoggy Delhi, “New York Times”, Jan. 26, 2014

Hellman A., Caseload, Conflicts, and Decisional Capacity: Does the Supreme Court Need Help?, 67 “Judicature” 1983

Hogg P. W., Constitutional Law in Canada, 4th ed., 2002

Horwitz M. J., The Transformation of American Law 1780–1860, 1977

Issacharoff S., Class Actions and State Authority, 44 “Loyola University of Chicago Law Review” 2012

Kagan R., Adversarial Legalism: The American Way of Law, 2001

Lach K., Sadurski W., Constitutional Courts of Central and Eastern Europe: Between Adolescence and Maturity, (in:) Harding & Leyland

Leo Levin A., Amsterdam A. G., Legislative Control Over Judicial Rule-Making: A Problem of Constitutional Revision, 107 “University of Pennsylvania Law Review” 1958

Livingston D. L., The Civil Rights Act of 1991 and EEOC Enforcement, 23 “Stetson Law Review” 1993

Lollini A., The South African Constitutional Court Experience: Reasoning Patterns Based on Foreign Law, 8 “Utrecht Law Review” 2012

Marcus R. L., Appellate Review in the Reactive Model: The Example of the American Federal Courts, (in:) A. Uzelac, C. H. van Rhee (eds.), Nobody’s Perfect: Comparative Essays in Appeals and Other Means of Recourse Against Judicial Decisions in Civil Matters, 2014

Marcus R., Exceptionalism and Convergence: Form versus Content and Categorical Views of Procedure, (in:) J. Walker, O. G. Chase (eds.), Common Law, Civil Law, and the Future of Categories, 2010

Marcus R., They Can’t Do That, Can They? Tort Reform Via Rule 23, 80 “Cornell Law Review” 1995

Martin M. M., Inherent Judicial Power: Flexibility Congress Did not Write Into the Federal Rules of Evidence, 57 “Texas Law Review” 1979

Merrill T., The Common Law Powers of Federal Courts, 52 “University of Chicago Law Review” 1985

Nelson Moore K., The Supreme Court’s Role in Interpreting the Federal Rules of Civil Procedure, 44 “Hastings Law Journal” 1993

Oakley J., Coon A., The Federal Rules in State Courts: A Survey of State Court Systems of Civil Procedure, 61 “Washington Law Review” 1986

Ponthoreau M.-C., Hourquebie F., The French Conseil Constitutionnel: An Evolving Form of Constitutional Justice, (in:) Harding & Leyland

Seligman J., The Merits Do Matter, 108 “Harvard Law Review” 1994

Sherman E., The MDL Model For Resolving Complex Litigation If A Class Action is Not Possible, 82 “Tulane Law Review” 2008

Stephens B., The Curious History of the Alien Tort Statute, 89 “Notre Dame Law Review” 2014

Stevens T., Williams G., A Supreme Court for the United Kingdom? A View from the High Court of Australia, 24 “Legal Studies” 2004

Stone A., Abstract Constitutional Review and Policy Making, (in:) D. W. Jackson, C. Neal Tate (eds.), Comparative Judicial Review and Public Policy, 1992

Struve C. T., The Paradox of Delegation: Interpreting the Federal Rules of Civil Procedure, 150 “University of Pennsylvania Law Review” 2002

Sunderland E., The English Struggle for Procedural Reform, 39 “Harvard Law Review” 1926

Sutton J. S., Courts As Change Agents: Do We Want More or Less?, 127 “Harvard Law Review” 2014

Tocqueville A. de, Democracy in America 93, H. C. Mansfield, D. Winthrop translation, University of Chicago Press (2000) (originally published in 1835)

Similar publications