Abstract
Abstract This Chapter analyses and accounts for the different amounts spent on legal aid in a selection of developed countries. It starts by describing the limits and success of three legal aid movements: the right to counsel codification in European Continental codes, the peace of law movement in Germany around the turn of the century and the legal aid movement in some of the welfare states of the 1970s. Explanations are sought for why legal aid grows in some countries but meets resistance in others under similar circumstances. As main factors, the prosperity of the welfare state and the success of lawyer lobbies in defending professional privilege are singled out. They provide the key to explaining why Canadian provinces or Australian states have, but American states have not (and why Scandinavian countries and the Netherlands have, but Germany or France have not) invested in legal aid infrastructures. The way legal aid institutions are embedded within the welfare system and in the legal profession also explains why current austerity politics have managed to put a ceiling on Dutch and Scandinavian expenditures but not on the British legal aid scheme.
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