^aCenter for the Study of Law and Society, University of California, Berkeley, CA 94720-2150, USA. E-mail: rak@berkeley.edu

Abstract

Legal changes stimulated by economic liberalisation and European Union governance have led some observers to speak of the 'Americanisation' of European law. Focussing on the dynamics of legal change and resistance in European member states, this article questions the extent of trans-Atlantic legal convergence, noting six important differences between European and American law that are unlikely to disappear.