Public Prosecutors in the United States and Europe

A Comparative Analysis with Special Focus on Switzerland, France, and Germany

  • Gwladys Gilliéron

Table of contents

About this book


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.


Comparative study Procedural guarantees Prosecution services Prosecutorial power Simplification of procedure

Authors and affiliations

  • Gwladys Gilliéron
    • 1
  1. 1.Fernuniversität Schweiz Rechtswissenschaftliche FakultätBrigSwitzerland

Bibliographic information