Abstract
National legal systems are very complicated creatures, resistant to simple generalizations, and in democratic nations, they surely have more shared features than divergent ones. I have argued, however, that compared to other constitutional democracies, policy implementation and dispute resolution in the United States are distinctive in the degree to which those processes are pervaded by adversarial legal contestation.' In response, some observers argue that the rest of the economically developed world is moving inexorably toward convergence with American adversarial legalism, pushed in that direction by more competitive global markets, the weakening of the welfare state, and the growth of transnational European government. That 'convergence' argument raises the broad questions addressed in this essay:
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