Hacker News Reader

Comment by alan_cx | Hacker News Reader

I'm in the UK, no idea where you are. I don't trust my government one bit with my data, or any one elses. The US so called justice system literally scares the hell out of me. From a UK perspective, its terrifying. Unfortunately for UK subjects, the UK government willingly hands our data over to the US government, and equally willingly allows us to be extradited on little more than a request. Being a European Citizen offers us in the UK very little protection from the US.

As others have said, I have very little problem with the likes of google and MS having a lot of data on me, as long as they use it fairly and reasonably, and Im kept informed. Of course we do have the problem of government access to that data.

View on HN

Out of curiosity, which aspect of the US leal system scares you so much? I was under the impression that UK has a rather similar legal system in many respects, and has a number of problems as well. Personally I am a little scared of the French and German legal systems. And last year I read a very scary article about the Swedish legal system on HN.

US is doing a lot of things wrong these days when it comes to privacy, but when compared to EU, I find it to be about the same.

By European standards prison sentences in the US are very very long. There is also a perception that in the US the system is loaded against people who don't have enough money to pay for a good lawyer.

I am not very familiar with penalties in EU, but I thought that on all the basics, like fraud, robbery, burglary, assault, murder, etc the penalties were comparable to US. Where US does go insane is when it comes to drug and gun crimes. The NRA lobbied for very stiff penalties for anyone who uses a gun in a crime, at least in CA. The drugs on the other hand are just a national obsession for people here in US, so I get that criticism. But on all the basics, I think EU and US are at parity. The Federal prosecutors are quite insane, but Obama has been trying to fix that, and many Federal judges are quite reasonable. But again, if US does need adjust something, it's the Federal system.

As for money and lawyers, US, at least in CA has excellent public defenders. I might be biased, because a few of my good friends are public defenders. But also the smartest man I ever meat, at least when it comes to law, was head Public Defender in San Diego. Public defender job in a major city is a very competitive position. That's my first hand experience in CA. Not sure about other states.

According to the prison documentaries I've seen EU penalties in general are much lower (like half to one third) than US ones for the named crimes. And we don't have death sentences over here so that changes perception a lot.

For instance this is robbery sentence guidelines in UK [1] and CA [2]. As you can see, penalties are very comparable. Robbery in CA is 2, 3, or 5 years or 3-9 years, depending on the degree, while in UK it's 2-7 years or 7 - 12 years, also depending on the degree. The first level of robbery in UK is more attune to Petty or Grand Theft in CA. In CA there is also a GBH enhancement, that will bump you up to the 12 years, just like in the UK.

Obviously, I have not done the comparison for all the crimes, but I think if done, we would find that EU and US both have very similar penalties for all the person crimes, like theft, robbery, rape, murder, etc. Where there is a big difference is probably in the crimes that have to do with national obsessions. For US it's drugs, guns, terrorism. For EU it's WW2 and holocaust, and also terrorism nowadays. But checking drug penalties in UK I also found them to be very similar to Federal statutes in US. [3] Though, if I had to guess, I would think the UK is far less likely to apply it's possession only laws. So, that's a valid criticism.

US does have an insane incarceration rate, but it's again due to our obsession with drugs. Take that out of the equation, and we are about even. Not that that makes it all ok, but I think we are on a path to changing that.

[1]http://www.cps.gov.uk/legal/s_to_u/sentencing_manual/robbery... [2]http://www.shouselaw.com/robbery.html [3]https://www.gov.uk/penalties-drug-possession-dealing

CA is not the whole of the US. It's one relatively liberal state. What about states in the midwest? What about federal crimes? What about three strikes legislation? What about CFAA? What about death sentences? What about felony murder?

The US may be fixing some of these things but for an idea of how the US system is viewed from over here right now check out the documentaries by Louis Theroux and the one entitled "The Farm -- Life on Angola Prison".

Reply on news.ycombinator.com