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A comment on We Are All Lawyers Now – The Rise of the Legalish. Parent comment

Re:We Are All Lawyers Now – The Rise of the Legalish by sandworm101 on Tuesday October 23, 2018 @09:24AM (#18283131)
The US obsession with loopholes and "letter of the law" is a historical religious thing. US is protestant, where the language of the bible is made availible to all. Everyone is free to read and invent an interpretation, to find thier own loopholes. Europe follows a more catholic tradition, where biblical language is interpreted through priests. Hence, european judges (legal priests) are given more authority to interpret language and smooth out rough edges. It is centuries-old culture.
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Re:We Are All Lawyers Now – The Rise of the Legalish by twic on Tuesday October 23, 2018 @10:49AM (#18283824)
Ah yes, Martin Luther, that famous American. Who can forget when he inspired President Henry VIII to break with the Catholic church!
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Re:We Are All Lawyers Now – The Rise of the Legalish by ben_w on Tuesday October 23, 2018 @11:20AM (#18284105)
The distinction I’ve heard is called Roman law (continental) versus common law (UK, its colonies and empire).
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Re:We Are All Lawyers Now – The Rise of the Legalish by sandworm101 on Tuesday October 23, 2018 @11:33AM (#18284250)
Exactly, the UK being home of one of the largest protestant traditions (COE). The specifics of biblical language and translation is a cornerstone of English political and legal history (see Henry VIII and associated fiascos).

But when people speak of European colonial law v common law, they are normally talking about French v. British. The Napoleonic tradition followed in former french colonies is very different than the British common law. And there are places (Louisiana and Quebec) where these two legal traditions were forced to merge. When comparing the two we still see the catholic v protestant split, which is expected given the history. The french relationship with language, that there is a government agency to define words, also leans towards a more authoritarian view of legal interpretation. America today doesn't even have an official national language.

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