Gavin Howe
The United States and the United Kingdom have distinct legal systems, with each country having its own set of requirements and standards. Differences in law between the two countries can have real-life consequences, especially when contract law is concerned. For example, in the UK, written evidence is not always required for ordinary contracts, whereas written evidence is often called for in the US. The two countries also differ in their approaches to legal education, libel law, and the way laws are made and administered. For instance, in the UK, libel law requires the person who made the allegedly defamatory statement to prove that it was true, while in the US, the burden of proof rests with the person who claims to have been libelled.
| Characteristics | Values |
|---|---|
| Legal education structure | In the UK, students can opt for a three-year LLB program or an undergraduate degree plus a one-year GDL conversion course. In the US, students must take the LSAT, apply to law school, and study for a Juris Doctor (JD) degree in law. |
| Tuition fees | Tuition fees for a law degree are typically higher in the US than in the UK. |
| Living costs | Living costs, including accommodation, food, transport, and books, are generally higher in the US than in the UK. |
| Financial aid | Financial aid options are more limited in the UK compared to the US. |
| Legal system | The US has a Constitution, federal laws, state laws, and local laws, with each state having its own laws and courts. The UK has one body of laws, with some variations in Scotland and Northern Ireland. |
| Libel laws | In the US, public figures cannot sue for honest but unfair and untrue criticisms. In the UK, published facts must be true, and the burden of proof rests on the person who made the allegedly defamatory statement. |
| Contract law | Contract law differs between the US and UK, particularly regarding the enforcement of contracts by third parties. |
| Property and income | Most common-law countries, including the UK, allow judges to use their discretion in reallocating property and income during spousal separation. Some American states adhere to the principle of equal division of assets. |
| Criminal records | In the UK, court convictions cannot be deleted from criminal records. In the US, certain criminal records can be sealed or expunged by a judge. |
| Cannabis legality | Cannabis has been legalized in 21 US states and decriminalized in 10, while it is a Class B drug in the UK with harsh penalties for supply, although it has been legalized for medical use. |
| Road crossing laws | In the UK, except for Northern Ireland, there are no laws about how pedestrians can cross roads. |
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What You'll Learn
Legal education structure
The United States and the United Kingdom have distinct legal education structures, with their own sets of requirements and standards.
In the UK, students aspiring to become lawyers have two main paths to choose from. The first option is to complete a three-year LLB program, which is specifically designed for law studies. The other option is to pursue an alternative undergraduate degree in any field and then take a one-year GDL (Graduate Diploma in Law) conversion course. The GDL is an intensive program that covers the same content as the LLB course in a shorter duration. Following the completion of their LLB or GDL, students can further their legal education by undertaking either the Bar Professional Training Course (BPTC) or the Legal Practice Course (LPC). The BPTC is intended for aspiring barristers, while the LPC is geared towards those who aim to become solicitors. Both of these courses span a period of one year, focusing on specific areas of law. As of 2021, a new qualification pathway, the Solicitors Qualifying Examination (SQE), is being introduced. It consists of two stages of exams, SQE1 and SQE2, which are mandatory for individuals aiming to qualify as solicitors. Additionally, the Master of Laws (LLM) is a postgraduate qualification available for students who want to delve into a particular area of law without necessarily becoming practising solicitors or barristers.
In the US, the legal education structure differs significantly. Students must take the LSAT, which assesses reading comprehension, logical reasoning, and pattern recognition skills, before applying to law school. After completing an undergraduate degree, accepted students pursue a Juris Doctor (JD) degree in law, which typically takes three years to finish. This degree does not differentiate between types of lawyers. Subsequently, students often pursue a law master's degree, known as an LLM, which usually takes around nine months to a year to complete. This program focuses on research and analytical study of the law. US law schools offer a wide array of courses and electives, allowing students to tailor their education to their specific interests. Additionally, practical experiences, such as moot court competitions and internships, are encouraged in the US legal education system, fostering the development of skills and professional connections.
The tuition fees for law degrees are generally higher in the United States compared to the United Kingdom. In the US, the average tuition costs range from $11,260 (public four-year, in-state) to $41,540 (private non-profit four-year), while in the UK, tuition fees for British students are typically around £9,250 per year, with international students paying between £10,000 and £26,000 annually.
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Libel laws
Under UK law, the burden of proof rests on the person who made the allegedly defamatory statement to prove that it was true. Notably, companies are treated as "legal persons" and can sue for libel just as natural persons can. In addition, there is no burden to prove damage to reputation in libel cases, although this generally needs to be proven in slander cases.
In contrast, US practice is considered less strict than the UK when it comes to libel. In the US, public figures cannot sue for honest but unfair and untrue criticisms of their activities. The burden of proof rests with the person who claims to have been libelled, who must prove that the statement made about them was false.
The differences in libel laws between the two countries have had real-world consequences. For example, the cyclist Lance Armstrong employed a UK law firm to help him fight allegations of doping by leveraging UK libel law. Conversely, Emma O'Reilly, a masseuse who worked with Armstrong's cycling team, claimed that English libel law prevented her from speaking out about the doping she witnessed.
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Farming and meat processing
There are several differences between the UK and the USA when it comes to farming and meat processing. In the USA, food safety regulations are enforced by several agencies, including the Food and Drug Administration (FDA), the United States Department of Agriculture (USDA) Food Safety and Inspection Service (FSIS), and the Centers for Disease Control and Prevention (CDC). On the other hand, food safety in the UK is regulated by a single government body, the Food Standards Agency (FSA), which was established in 2000. The FSA is responsible for overseeing farming practices, animal welfare, production hygiene standards, and nutritional guidelines for citizens.
One notable difference between the two countries is their approach to animal welfare. The UK has legally recognised the sentience of animals since 1875 and has introduced several regulations to improve animal welfare in slaughterhouses, such as the Animals Act of 1911 and the 2006 Animal Welfare Act. In contrast, legislation on animal welfare in the USA is lacking, with very few federal regulations and only weak and inconsistent state-level regulations. This has led to concerns about poor animal welfare standards in US farming practices.
Another difference lies in the use of antibiotics in livestock farming. While antibiotic use is common in both countries, the types and amounts permitted vary significantly. Farmers in the USA are generally allowed to administer higher and more frequent doses of antibiotics to their livestock compared to the UK. According to research, US livestock receives an average of 5.4 times more antibiotics per animal than their counterparts in the UK. The UK government actively works to reduce antibiotic use in livestock farming to combat the issue of antibiotic resistance.
The use of pesticides also differs between the two countries. The USA has weaker standards when it comes to pesticide residues in food, with some pesticides being used that are banned in the EU and the UK. A study found that in 2016, the USA was still using 72 pesticides that were prohibited in the EU. This is due to the Environmental Protection Agency (EPA), which controls pesticide use in the USA, relying heavily on the decisions of the farming industry.
Additionally, there are differences in the washing and disinfecting processes of meat. In the USA, it is common to chemically wash poultry with chlorine to kill microorganisms that may cause illness. However, this practice is banned in the UK and the EU as there are concerns that it may be used to compensate for poor hygiene and animal welfare standards earlier in the meat production process.
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Cannabis legislation
However, the UK has legalised cannabis for medical use. Following legislative changes in 2018, it became easier to prescribe and supply medicinal cannabis products. The General Medical Council issued interim prescribing guidance, and the National Institute for Health and Care Excellence (NICE) provided guidelines for prescribing cannabis-based medicinal products for specific conditions. Additionally, CBD is not a legally controlled cannabinoid in the UK, so the possession and supply of pure CBD oil do not require a Home Office licence, although it may need to comply with other product regulations.
In terms of production, the UK government grants licences for cultivating and processing cannabis and provides support services for growers and processors of cannabis for fibre. The UK is a significant exporter of legal cannabis, catering to the medical market.
The differences in cannabis legislation between the two countries can be attributed to their distinct legal systems. The USA has a federal system with federal, state, and local laws, while the UK has one body of laws with some variations in Scotland and Northern Ireland. These variations contribute to the disparities in how cannabis is regulated and enforced in each country.
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Court conviction records
The United States and the United Kingdom have distinct approaches to maintaining court conviction records. In the UK, there is a single body of laws, with some variations in Scotland and Northern Ireland. The US, on the other hand, has federal laws, state laws, and local laws, resulting in legislative variations across states.
In the UK, historical records of prisoners are kept in various places, including The National Archives, prisons, and local archives. The National Archives contain lists and registers of prisoners submitted to the Home Office or Prison Commission. Prison records, if available, can be found in local or county archives. The Prison History website offers information on 19th-century prisons and lock-ups, while the Digital Panopticon website provides details on convicts from the Old Bailey (Central Criminal Court). For current prisoners, the prisons and probation pages on GOV.UK offer information.
In the US, each state maintains its own records, and legislation varies across states. The US National Employment Law Project estimates that as of 2011, approximately 65 million US citizens had a criminal record, or about 1 in 4 people. This has led to challenges in finding employment and obtaining travel visas for Americans with criminal records.
Differences in libel laws between the two countries also affect court conviction records. In the UK, the defendant must prove that their statement was true, whereas in the US, the burden of proof rests on the claimant, who must demonstrate that the statement about them is false. This distinction has resulted in a phenomenon known as "libel tourism," where individuals seek to protect their reputations by bringing libel claims in the UK. However, this practice has decreased as British courts now require claimants to show that a defamatory statement caused "serious harm."
Another difference between the two countries' legal systems is their treatment of cannabis. In the US, cannabis has been legalised in 21 states and decriminalised in 10, while in the UK, it is a Class B drug with potential fines and penalties for possession and harsher consequences for supply. However, the UK has legalised medical cannabis since 2018 and is a significant exporter.
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Frequently asked questions
In the UK, students who want to become lawyers can complete a three-year LLB program or an undergraduate degree and a one-year GDL conversion course. In the US, students must take the LSAT and apply to law school after completing their undergraduate degree. Accepted students study for a Juris Doctor (JD) degree in law, which takes three years.
The US has a Constitution, and its legislative functions operate at different levels. There are federal laws, state laws, and local laws. Each US state has its own laws and courts, so legislation can vary. In the UK, there is one body of laws, with some variations in Scotland and Northern Ireland.
In the UK, there is no legal process to delete court convictions from a person's permanent record. In the US, certain criminal records can be sealed or expunged entirely by a judge. Another example is in libel law; in the US, the burden of proof rests with the person who claims to have been libelled, whereas in the UK, it is up to the person who made the statement to prove that it was true.
