美国与德国法官选任制度之比较

美国与德国分别为两大法系的典型代表国家。两国的司法制度均显著体现其各自的历史渊源和法律文化背景 ,同时又成功地服务于法治国家的运行 ,其中许多成熟的理论与实践经验值得我们探讨和借鉴。通过对两国司法制度中的一项关键性问题———法官选任制度做比较式探讨 ,展现两国在法官选任程序与选任资格方面严格科学的制度设置 ,可为我国当前法院体制改革提供有益借鉴

An American-Germen Comparison of Selection of Judges

America and Germany represent two legal families respectively. The judicial systems in the two countries are characterized by their own historical traditions and legal cultures and serve the operation of rule of law successfully. There is much theoretical and practical experience, which deserves being learned and introduced. Through a comparative study on the election of judges, which is the key in the two countries judicial systems, their scientific system setting about the election procedure and the qualifications are deeply discussed, which may be conducive to the reform of the systems in court in China.