@article{697912,
      recid = {697912},
      author = {Gilliéron, Gwladys,},
      title = {Public prosecutors in the United States and Europe a  comparative analysis with special focus on Switzerland,  France, and Germany / [electronic resource] :},
      pages = {1 online resource (xxiv, 362 pages) :},
      note = {"Habilitation thesis of the faculty of Law of the  University of Zurich 2013."},
      abstract = {This research examines the role of prosecutors within the  United States and in Switzerland and is completed by an  overview of the prosecution institutions in France and  Germany. The research recognizes that despite seemingly  very different legal traditions and structures, prosecutors  in these systems are similar enough that each system might  learn from the others. Drawing upon the experiences of  other nations, this research proposes solutions to the  problems identified in connection with the position and  powers of public prosecutors in the United States.  Furthermore, it outlines the problems related to the  increase of prosecutorial power and the lessons the  European criminal justice systems surveyed can draw from  the experience in the US. In terms of methodology, this  research not only considers formal legal provisions but  also systematic structural factors, academic literature and  statistics revealing how the law and governing principles  actually work in practice.},
      url = {http://library.usi.edu/record/697912},
      doi = {https://doi.org/10.1007/978-3-319-04504-7},
}