comparative analysis of the French and American judicial systems and the cultural effects of judicial decisions

The histories of France and the United States of America are often compared alongside the judicial systems of each country. While the histories of the countries, starting with the French and American revolutions, have similarities, the judicial systems themselves are based on different schools of thought. The French method of judicial decision making is based on the Napoleonic code whereas the American method is based on that of common law. In available literature regarding comparisons of France and the United States, it is an assumption that, if the American and French judicial systems are based on different legal theories, the cultural effects of those systems must also be different. Contrary to these expectations, however, my analysis of court cases focusing on labor unions' right to strike demonstrates that there are similarities in judicial decisions' effects on society.