Public Prosecutors in the United States and Europe : A Comparative Analysis with Special Focus on Switzerland, France, and Germany

La 4e de couverture indique : "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." Front Matter....Pages i-xxiv Aim, Approach, and Methodology of the Study....Pages 1-8 Methods for Coping with Overloaded Criminal Justice Systems....Pages 9-13 The Criminal Justice Systems Studied....Pages 15-38 History of the Public Prosecutor....Pages 39-64 Public Prosecutors in the United States: Position, Powers, and Accountability....Pages 65-169 Public Prosecutors in Switzerland: Position, Powers, and Accountability....Pages 171-262 Overview of Public Prosecutors in Germany: Position, Powers, and Accountability....Pages 263-285 Overview of Public Prosecutors in France: Position, Powers, and Accountability....Pages 287-312 Comparative Overview of Position, Powers, and Accountability of Public Prosecutors....Pages 313-331 Thematic Problems and the Prospects for Reform....Pages 333-342 Conclusion....Pages 343-345 Back Matter....Pages 347-362 Aim, Approach, And Methodology Of The Study -- Methods For Coping With Overloaded Criminal Justice Systems -- The Criminal Justice Systems Compared -- History Of The Public Prosecutor -- Public Prosecutors In The United States : Position, Powers, And Accountability -- Public Prosecutors In Switzerland : Position, Powers, And Accountability -- Overview Of The Public Prosecutors In Germany : Position, Powers, And Accountability -- Overview Of Public Prosecutors In France : Position, Powers, And Accountability -- Comparative Overview Of Position, Power, And Accountability Of Public Prosecutors -- Thematic Problems And The Prospects For Reform -- Conclusion. Gwladys Gilliéron. Habilitation Thesis Of The Faculty Of Law Of The University Of Zurich 2013 -- Title Page Verso. Includes Bibliographical References.