WORLD FACTBOOK OF CRIMINAL JUSTICE SYSTEMS INTRODUCTION Graeme Newman, Adam C. Bouloukos, and Debra Cohen The goal of this Factbook is to provide up-to-date information about the criminal justice systems of the world. Information is provided with a level of detail sufficient to convey a reasonably accurate snapshot of the criminal justice system for the interested professional who is, perhaps, travelling to the country for the first time, or who needs a quick overview of the country's criminal justice system for research or planning purposes. In this regard, it should be used in conjunction with other Factbooks, such as the CIA Factbook, which provide basic economic, political, military, and cultural information about the countries. Descriptions have been collected for a number of countries around the world and will be added to the ones presented here as they become available. While each description varies in the level of detail provided, all conform to a basic template that was developed in order to organize both the collection and the presentation of the information. Development of this template was a particularly difficult undertaking, because it raised some basic questions about criminal justice. Namely, what is a criminal justice system, and once answered, what are the essential elements of the system for which information should be collected from every country? Intrinsic to this problem, of course, was the challenge to develop a template that would apply "equally" to every country, regardless of how its criminal justice system was organized or structured. What Is A Criminal Justice System? What is Criminal Justice? The expression "criminal justice," was born of the mid-20th century in the United States. The first school of criminal justice was established at the State University of New York at Albany in the 1960s, and the curriculum of that school has been used as a blueprint for many schools and departments in Universities and training organizations in many parts of the world. The curriculum of these schools is usually divided into several main subject areas: Administration of (Criminal) Justice; The Nature of Crime and/or Criminology; Corrections and/or Penology; Criminal Law and Procedure, and Research Methods and Statistics. While there are many variations on these themes, and there continues to be much controversy as to the scope of such curricula, it can be seen that these five parts of the typical criminal justice curriculum reflect, generally, the late 20th century approach to the understanding of crime and justice. Prior to this century, the approach to criminal justice was more oriented toward an assessment of the legal aspects of crime, with the scientific aspects of criminal justice being mostly confined to the study of the causes of crime, and not to the actual operations of the criminal justice system. In the Western tradition of criminal justice, it might be argued that Beccaria's famous treatise, "On Crimes and Punishments," focused almost entirely on the administration of criminal justice, and not on causes of crime. In this sense he might be thought of as the "father" of criminal justice in the same way that Lombroso is often thought of as the "father" of scientific criminology. Many American textbooks of criminal justice typically begin with a flow diagram of the criminal justice system, showing the movement of cases and/or offenders, beginning with the first contact with the police, through the many paths of criminal justice, to some final outcome. Along the way to this end, there are many different persons including lawyers, human service workers, government and non-government employees, politicians and elected officials who can play a role in the process. In fact, the complex diagrams of the American textbooks are themselves highly simplistic, since they cannot possibly portray the detail of the multi-layered systems of criminal justice that exist throughout the United States. The independence of each state means that each has its own criminal justice system, so that there are 50 different criminal justice systems in the United States, not including the Federal system and the District of Columbia. But even this is misleading, since there are also criminal justice agencies (including police, courts and jails) that operate entirely, and independently, at the local (city, town and county) level. These diagrams have become more and more complex in recent years, showing the many different routes offenders and suspects may take through the "system." New "parts" tend to be added to the system diagram as new ways of "diverting" and/or "treating" offenders are introduced, and as the scope of criminal justice is broadened to encompass different types of offenders and offenses. This highly theoretical but effective way of portraying criminal justice as a well integrated system, was first introduced in the Crime Commission report, "Challenge of Crime in a Free Society," in 1966, which was issued directly from the Johnson administration's push toward the Great Society. Prior to this time, the various aspects of criminal justice were seen as separate and distinct enterprises; police, courts, and corrections were seen as largely independent bodies (Duffee, 1990; Walker, 1992). What is a System? Strictly speaking, the criminal justice system is not a "system," in the same way that one might consider an automobile engine. There, every part depends on every other part for its smooth functioning and the clear singular purpose of powering the automobile. The criminal justice system does not often have a clearly defined overall goal, and in fact, its various parts may have conflicting goals. For example, the goal of the corrections department may be to treat its prisoners according to the United Nations Standard Minimum Rules for Treatment of Prisoners. But the court system may deliver to it too many offenders with long sentences, resulting in prison overcrowding. Nor is it agreed upon as to what the actual goal of a prison ought to be (e.g., rehabilitation, penance, or custody). As a further example, it is not uncommon for police to view courts as being counterproductive to their work by letting too many offenders go free, or in treating them too leniently. If the various parts of the criminal justice system (police, courts, corrections) work as a system, they do so only as a very loosely tied group of subsystems within subsystems. Their operations are often only tenuously linked. The United States criminal justice system represents, arguably, the most difficult case from the point of view of comparative criminal justice, because of its incredibly complex, multi-layered system. Those countries with a more unitary system of government are able to portray their criminal justice operations more completely and succinctly. Because of the high degree of abstraction necessary to portray and conceive of the U.S. system of criminal justice as a "system", contributors were given a template laid out according to what was deemed the essential "stages" or "elements" of criminal justice. The template stayed quite close to the traditional American view of criminal justice as beginning with police contact, then courts, and finally corrections, rather similar to the "contemporary criminal justice paradigm" as described by Walker (1992). While this approach seems obviously biased in favor of the common law legal system, it can be justified, because the Factbook is a collection of descriptions of criminal justice systems, not legal systems. This is an important distinction that needs to be clarified, because the modern criminal justice system originates not so much from a particular legal system, but rather from the concept and operation of the modern nation-state. The two--legal system and nation-state--are closely linked. However, it is the nation-state that gives force and legitimacy to the legal system, and provides the essential operational foundations (i.e. the resources, both human and economic) for the criminal justice system to operate. This requires some elaboration particularly in regard to previous attempts to link criminal justice systems of the world to specific types of legal systems or "families of law." Legal Systems and Criminal Justice Previous writings that have tried to compare the criminal justice systems of different countries have virtually all rooted themselves in the identification of various types of legal systems or rules of law (See for example, Cole et al, 1987; Terrill, 1984; David and Brierley, 1968). Generally speaking, such studies claim that there are basically three legal families in the world: civil law, common law, and socialist law. First, civil law refers to the Romano-Germanic family of law where "rules of law are intimately linked to ideas of justice and morality...[This family] attache[s] special importance to enacted legislation in the form of "codes" (David and Brierly, 1968:22). Second, common law is historically English and is premised on the notion that judicial decision "seeks to provide the solution to a trial rather than to formulate a general rule of conduct for the future. It is, then, much less abstract than [civil law]" (David and Brierly, 1968:24). Third, law in the socialist society is "strictly subordinate to the task of creating a new economic structure... [In fact], the proclaimed ambition of socialist jurists is to overturn society and create the conditions for a new social order in which the very concepts of state and law will disappear (David and Brierly, 1968:26). There is also some, though not much, recognition of other systems of law: "Asian," "Islamic" and "Hindu" (David and Brierley, 1968). Since the people of the world who live under these three systems comprise roughly half the world's population, it is difficult to avoid Beirne's charge of "legal chauvinism" (1983) against such writers. From the point of view of legal systems and the idea of law, perhaps this charge is justified. However, from the point of view of criminal justice systems, we do not think that it is, for reasons that we shall make clear shortly. For the moment, we question the wisdom of making too much of the division between the civil law tradition and that of common law. While it is true that the common-law tradition emerged in England after the Norman invasion in 1066, nevertheless there are many roots of English common law in previous European legal history. The Latin terminology retained in all Western law, both civil and common, surely attests to its origins in European culture and philosophy. Similarly, the attempt to separate socialist law from the civil and common law is misguided at best. The fact is that Marxist theory has no room whatsoever for the concept of law. The emergence of socialist law is an aberration of civil law, not a "new" or independent body of law. Aberration is meant simply as a re-affirmation of the inquisitorial aspect of the history of the civil law family: law's appropriation by a politically powerful autocracy to further its own interests. Such occurred during the Inquisition of the Middle Ages, as well as during the Marxist era of the 20th century. While the actual content of socialist law may appear different, its functions and operations remained an accentuated version of civil law with a heavy emphasis on a control model of criminal justice (See Packer, 1968). It is the latter observation of "socialist law" that suggests a differentiating factor: the needs of the state to establish an operational mode on top of the legal system. Thus, it is the demands of the state that produce the basic structures of criminal justice systems, not the legal system or law per se. An excellent example of this complex relationship between legal systems and criminal justice may be seen in the case of the United States itself. The United States criminal justice system is commonly held to have its roots in English common law. Also noted is the incredible diversity of criminal justice systems within the United States. These systems are, however, tied together by the overarching political structure of the United States federal system of government, with its built in "checks and balances". Of equal or greater importance in binding the diverse systems is the United States Constitution. Further, the Constitution is based on an even deeper philosophical (some would say cultural) binding force: the rule of law. This "legal principle provides that decisions should be made by the application of known principles or laws without the intervention of discretion in their application" (Black, 1990: 1332). This principle, while it serves to bind different systems together under one "goal", says nothing about the organizational structure required in order to implement the ideal. It does, however, require that there be formal systems for the identification of crime and societal reactions to it. That is to say, the concept brings with it the profoundly Western solution to crime: formal punishment. This "rule" therefore is as much socio-cultural in origin as it is legal. Thus, the formal criminal justice model that we have used in our template is clearly based on this widely identified rule of law along with its correlatives: the official finding of guilt and the response of punishment and/or corrective sanctions in one form or another. Anthropologists of law have taught us that this concept of social control is distinctly Western (though not only Western). In many cultures, historically and currently, the idea of formal law, both written or unwritten, does not or did not exist (See, for example, Hoebel (1954); Malinowski (1926)). But these observations of anthropologists are based on studies of cultures, rather than nation-states, and it is this fact that sets a book such as this apart from the traditional work of the anthropologists of law. Furthermore, it is no coincidence that the U.S. criminal justice system is based on English common law. It was, of course, a colony of the newly emerged nation-state of England. Many of the countries surveyed in this book are former colonies of Western powers (Western defined broadly to mean those powers of Europe that emerged in the 16th century--see below). But a country does not need to have been colonized by one of the western powers in order to have its criminal justice structure influenced by the West. The reason for this is that the very concept of the nation-state, to which all countries of the world today claim status, is a Western concept, and a product of relatively recent Western history. Criminal Justice and the Nation-State. The concept of the modern nation-state emerged in Europe roughly in the 16th century, and it was this powerful concept that drove these nations (e.g., England, Spain, France, Portugal, Holland) to expand and impose their national identities on other countries. The colonized countries, while often more advanced in other respects (e.g. China technologically), did not conceive of themselves as "one nation," and so became vulnerable to attack by a Western power, with a unified and highly charged political concept of its own "sovereignty." It is the dominance of both the concept and legal entity of the nation-state that has demanded the formal structures of the criminal justice system. All the countries mentioned above developed the various parts of what we call the criminal justice system today--police, courts, prisons--at roughly the same time that they emerged as nation-states. Social historians and critics alike are clear on their identification of this period as contiguous with the rise in complex organizations and bureaucracies (Weber, 1978; Foucault, 1977) in regard to many aspects of social and economic life. Crime and its control were clearly a part of this massive change in the way in which States were organized and structured. Thus, while the actual legal systems may form the basis for the particular modes of decision making in the various countries (e.g. the civil law tradition in contrast to the common law tradition), all modern nation-states have formal systems of law, police forces, prisons, and court systems, regardless of the ethnic, cultural, or religious background of the country. All nation-states, as part of their very definition, seem to require such formal (criminal) justice structures. That both the concept and legal entity of the "nation-state" are distinctly Western, there can be no doubt. One needs merely to look at the basic charter of the United Nations to see that it emerged from the basic concerns of sovereignty of the Western powers (including the USSR) as a result of the conflict among major nation-states of World War II. If the events of the last 10 years are any indication, the push for the establishment of new nation-states and their demand for the United Nations recognition has never been stronger. The number of new states that have emerged in just the past 5 years is stunning. Thus, the World Factbook of Criminal Justice Systems is state-based, not culture-based, although the cultural aspects of nation-states may strongly influence the criminal justice system. However, at least for the criminal justice descriptions obtained for the Factbook, all countries, no matter what their political or cultural history, have police forces, all have courts of law, and all have prisons. This is quite remarkable in itself, especially since the recent emergence of new nation-states has been based on their reaffirmation of separate cultural and ethnic identities. The formal attributes of criminal justice (police, courts and corrections) have continued to exist, sometimes in stark relief. There are, of course, wide variations in the extent to which these formal attributes of criminal justice exert influence in the overall social control of a particular country. It might be argued that, in some countries (e.g., Japan) the formal aspects of the criminal justice system (police, courts, corrections) play a very small part in he overall social control of its society. The Factbook cannot hope to make this determination. It can only present the general description of the criminal justice systems of each country and provide some political and historical context for the system description. Obviously, the comparative weight of other social control institutions or systems--such as education, manners, family discipline and structure--must be determined on their own merits. Any comparisons of criminal justice systems across countries would, of course, need to take such factors into account. The Criminal Justice Model The model adopted, then, is a clearly Western model of criminal justice, one that it not far from the American model. This is justified by the predominance of the Western criminal justice model at this point in world history. It must be emphasized that it is a Western criminal justice system model that dominates the world, not a Western legal system model. Should it happen that modern nation-states begin to dismantle their prison systems, and abolish their police departments, then we the template would have to be reconsidered. But there does not appear to be any indication that such basic changes are under way. In fact, if anything, there is every indication that the model presented in this book is expanding and becoming more entrenched. It is true that there is a continuing search in many countries for "alternatives" to criminal justice, but so far, these alternatives tend to become subsumed within the formal structures of criminal justice. These are embellishments to the basic model of criminal justice, not replacements of it. Until or unless the historically recent concept of the nation- state recedes, the Western model of criminal justice will remain dominant. And so, it is within this model, that we have constructed our template for the description of the criminal justice systems. This approach, while it may be criticized for its obvious Western orientation, nevertheless carries with it an important advantage; it allows, perhaps paradoxically, for the descriptions of criminal justice systems in countries that do not fall easily within the traditional "big three" families of law (i.e., civil, common, and socialist). The introductory sections included outline the political and legal structure and the history of the respective criminal justice system to help account for the unique aspects that may help to bind the many parts of a given criminal justice system together, and to show the extent to which a criminal justice system plays a part in the overall social control of a country. The section on crime definitions and statistics, in order to provides some basis of "output" of the criminal justice bureaucracies of the modern nation-state. Finally, while some contributors complained that the template assumed a legal model that did not fit their particular country (for example, the concept of "arrest" does not exist as a concept in some countries), they nevertheless were able, within the categories provided them in the template, to express this difficulty and show how their particular system affected decisions made along the flow of the the criminal justice system. More substantially, the whole concept of a criminal justice system as portrayed in the template does not begin to address the many informal, customary, and traditional justice "systems" that exist in many countries. An efforst was made to make room for such systems within the template, but it is true that the template itself dominates the entire picture, and focuses essentially on formal aspects of criminal justice. As argued above, this is because the focus is on nation-states, not cultures. A Note on Contributors, Sources and Selection of Countries Selection of Contributors. Contributors, as far as possible were selected on the basis of their status as independent scholars or researchers, whose records of research or professional work in criminal justice were outstanding. While most are or were citizens of the country that they wrote about, some were not. There were some who also were officials of their governments in various capacities. Where possible, the affiliations of the contributors are identified. Sources. Every effort has been made to list carefully, and in detail the sources of information. However, there have been some instances where the positions or identities of sources and have been protected at the authors' request. These have been for reasons of personal safety of the authors and/or sources of information. This is also why, in some instances, specific positions or addresses of individuals or sources have not been listed. Original language titles of articles and books have been kept. Not all have been translated into English. Selection of Countries. The Factbook project began with the hope of collecting information on all geographic areas of the world, and to a large extent this was done. Ultimately, however, the countries in this Factbook is represent a combination of the availability of a qualified person to write the entry and the contact and identification of such individuals through various networking arrangements--especially through contacts at international meetings of criminal justice, and through the world wide electronic forum, the United Nations Crime and Justice Information Network. CRIMINAL JUSTICE SYSTEM TEMPLATE General Note: In countries with a federal or decentralized system of justice, please try to give a general account of the overall system, but also provide examples from the different localities or provinces which demonstrate diversity, if this is a significant factor. SECTION I: GENERAL OVERVIEW 1. Political System. How the different parts of the criminal justice system are administered according to such systems as Federal, State, Commonwealth, Provincial, local administrations etc. Note the number of States or Provinces. 2. Legal System. Describe the type of legal system, if applicable, such as Adversarial, Islamic, customary, inquisitorial, colonial, common law, Marxist etc. If an informal justice system plays a significant part in the justice system, describe its extent and general mode of operation. 3. Brief History. Narrative on the history of the legal system, and criminal law in particular. Political and social context of criminal justice system. Significant legislation that has affected the criminal justice system. SECTION II: CRIME 1. Classification of crimes. þOutline the general legal classification of crime (e.g., are there basic distinctions between serious and less serious offenses, such as felony/misdemeanour, indictable/non-indictable offenses, crimes/delicts etc.) List the crimes that generally fall within each category. þNote the age of criminal responsibility. þDescribe drug offenses. For which drugs is it criminal either to sell or use (specify which)? 2. Crime Statistics For the crimes of murder, rape, a serious property offense, and a serious drug offense, provide statistics reported or recorded by the police, for the most recent year available. If these statistics are unavailable, provide either number of arrests or number of convictions for each crime. Specify which statistic is used. In addition: þProvide the definitions upon which the statistics are based and state the origin of these definitions (i.e., are they legal definitions, or "administrative" definitions used by the police for recording purposes). It is recognized that the above offense types may not specifically exist in some countries. Please choose the offense type that is closest. þState whether attempts are included in the statistic. þProvide complete bibliographical information on the sources of these definitions and statistics. þCrime regions: Name regions (e.g. inner-city neighborhoods, mountainous or isolated regions, edges of big cities), where particular types of crime are generally higher or more typical of that area. SECTION III. VICTIMS 1. What particular groups (e.g. ethnic origin, gender, age, regional), if any, are the most victimized by crime? Are there survey data available on victimization? If so, briefly describe the findings and provide bibliographical sources. 2. Number of victims' assistance agencies and type (e.g., rape crisis centers, compensation boards, whether state/private administered). 3. Describe the role, if any, of the victim in prosecution and sentencing. 4. Describe Victims' rights legislation, if any. SECTION IV: POLICE By "police" we mean: "public agencies whose principal functions are the prevention, detection and investigation of crime and the apprehension of alleged offenders" (The United Nations Definition). 1. Administration. Describe or diagram the chain of command, whence the police derives authority to act. Comment on relation to the military structure. Note the administrative structure: i.e. local, state, federal etc. Describe types of policing agencies (e.g. tax collection, immigration etc.) and how they are administered (e.g. local, state, federal etc.) 2. Resources. Please report the: þAnnual expenditure on policing. þNumber of police by ethnic origin and gender, most recent year. þNumber of police at different levels of organization, if applicable. (i.e., Federal, state, local etc.), most recent year. 3. Technology. Please report the: þAvailability of police automobiles, ratio of police to automobiles if possible. þAvailability of electronic equipment (e.g. computer aided dispatch, computer records, radio communications, radar, etc.). þTypes of weapons available, availability of bullet-proof vests, etc. 4. Training and qualifications. Describe: þThe months or years or hours required. þWho conducts the training (on the job, State police academy, college, etc.). þQualifications for appointment as new recruit. 5. Discretion. Generally describe the process police follow in handling suspects from initial contact through to the prosecutorial stage. Please provide information on the following specifics: þUse of force: under what conditions may police use force and/or deadly force? What weapons do police carry on their persons? (e.g. guns, baton, etc.). þUnder what conditions/constraints may police stop and/or apprehend a suspect? þWhat proportion of arrests are made without a warrant? þWhat factors are taken into account in the officer's decision to process the suspect further in the criminal justice system, or to take alternative action such as "cautioning".? Are there departmental guidelines of rules that the officer must follow? þUnder what conditions/constraints may police search or seize property? þWhat are the legal requirements for obtaining confessions? 6. Accountability. How are complaints against police behavior handled? Are there "watchdog" committees, judicial review etc.? SECTION V: PROSECUTORIAL AND JUDICIAL PROCESS 1. Rights of Accused. þWhat are the rights of the accused in the trial process (e.g., right to trial by jury, trial by judicial panel, right to plead guilty to lesser offense, etc.)? þWhat assistance is provided the accused in his/her defense (e.g., public defender system, eligibility for assistance etc.)? 2. Procedures. þWhat are the preparatory procedures for bringing a suspect to trial? e.g., judicial investigation, grand jury, police investigation and arrest. þWhat official conducts the prosecution of the accused? (e.g., police, district attorney, court appointed magistrate etc.) þAre there alternatives to going to trial (e.g., negotiated settlement, dispute resolution, "plea bargaining," medical or other kind of supervised/unsupervised treatment)? Describe how these alternatives may be chosen (e.g., discretion of prosecutor, judge, other criminal justice officials). þWhat proportion of prosecuted cases actually goes to trial? Does this proportion vary according to major offense types? 3. Pre-trial incarceration. þUnder what conditions is incarceration before or waiting trial allowed? þDescribe bail procedures or their equivalent, if applicable. þWhat proportion of the pre-trial offenders is incarcerated (estimates acceptable)? SECTION VI: JUDICIAL SYSTEM 1. Administration. Describe or diagram the heirarchy of courts from highest authority to the lowest. 2. Judges. þReport numbers of judges overall and according to level of court, and provide ethnic and/or gender breakdown if available. þDescribe how judges are appointed, their training and qualifications. 3. Special courts. List and briefly describe special courts such as juvenile, family, ethnic, religious, cutomary etc. that deal with criminal offenses. 4. Procedure. How are the majority of criminal cases "resolved" (e.g., trial, summary sentence, guilty plea, etc.)? What proportion of cases is settled by "guilty plea" and does this vary by major offense category? SECTION VII: PENALTIES AND SENTENCING 1. Sentencing process. Who determines the sentence? Is there a special sentencing hearing? Which persons (professional, victims, jury, psychiatrists, social workers, relgious persons, etc.) have input into the sentencing process? 2. Types of penalties. What different kinds of penalties are typically used? þList the range (e.g., fines, prison, probation, corporal punishment, house arrest, banishment, institutional treatment facility, public punishments, publicity, disenfranchisement, exile etc.), and if possible the classes of crimes to which these penalties are more commonly attached (i.e., is rape typically punished by prison, property crime by fines, etc.). þIs the death penalty allowed? If so, for what crime(s)? Method(s) of execution? How many executions in last 5 years? SECTION VIII: PRISON Note: For countries with federal systems, please provide information that shows the proportions of federal compared to state prison data. 1. Description. þNumber of prisons and their type (e.g., maximum security, minimum security, prison farms, juvenile, male/female/co-ed). þNumber of prison beds. þNumber of prisoners--daily average population; by ethnic origin and gender. þNumber of annual admissions. 1 þActual or estimated proportions of inmates incarcerated for: Crime Type Annual Daily Admissions Average Drug crimes % % Violent crimes Property crimes % % Other % % Total 100% 100% 2. Administration. þHow are prisons administered: federal, state, local, private etc.? þNumber of prison guards and their types, by gender and ethnicity if available. þTraining required, qualifications for appointment. þTotal expenditure on prison system per year. 3. Conditions. þAre remissions possible? Time off for good behavior, parole allowed? þAre inmates required to work, attend classes, etc.? þWhat amenities and privileges are/are not provided (e.g., visiting policies, weekend leave, group therapy, educational and vocational programs, medical assistance, etc.)? SECTION IX: EXTRADITION AND TREATIES þCan criminals or suspects be extradited to or from other countries? If so, please list the countries. þCan prisoners be exchanged or transferred to other countries? Please list the countries. þAre there any general conditions that govern these agreements, or are all these agreements specifically bilateral? SECTION X: SOURCES Please list ALL sources used in compling this report. These should include: þPublished documents with year, publisher, place and author. þUnpublished documents and reports with year, department, agency and authors, address and phone number of agency. þPersonal communication. State names, addresses and phone numbers, date of contact. REFERENCES Beirne, P. (1983). "Generalization and its discontents: The comparative study of crime". In I.L. Barak-Glantz & E.H. Johnson (eds.), Comparative criminology, Beverly Hills, CA: Sage. Black, Henry Campbell (1990), Black's Law Dictionary, 6th Edition. St. Paul, MN: West Publishing Company. Cole, George F., S. J. Frankowski, and M. G. Gertz, (1987) Major Criminal Justice Systems. Beverly Hills: Sage. David, R. and J. E. Brierley (1968) Major Legal Systems of the World Today. London: Free Press. Duffee, D., F. Hussey, and J. Kramer, (1978). Criminal justice: Organization, structure, and analysis. NJ: Prentice-Hall. Fairchild, E. (1993), Comparative criminal justice systems. Belmont, CA: Wadsworth. Feeley, Malcolm M. (1991), Court reform on trial: Why simple solutions fail. New York: Basic Books. Feeley, Malcolm M. (1973), "Two models of the criminal justice system". Law and Society Review, 7(3): 407-425. Foucault, M. (1977), Discipline and Punish. New York: Pantheon, Hoebel, E. Adamson (1954), The Law of Primitive Man. Cambridge: Harvard University Press. Malinowski, Bronislaw (1926), Crime and Custom in Savage Society. New York: Harcourt, Brace and Company, Inc. Milovanovic, Dragan (1994), The Sociology of Law, 2nd Edition. Albany, NY: Harrow and Heston Publishers. Packer, Herbert L. (1969), The Limits of Criminal Sanction. Stanford, CA: Stanford University Press. Terrill, Richard J. (1984), World Criminal Justice Systems. Cincinnati: Anderson Publishing Company. Von Glahn, Gerhard (1986), Law Among Nations. New York: Macmillan Publishing Company, Inc. Walker, Sam (1992), Origins of the contemporary criminal justice paradigm: The American Bar Foundation Survey, 1953-1969. Justice Quarterly, 9(1): 47-76. Weber, M. (1978), Economy and Society, Vol 1 and 2, G. Roth and C. Wittich (eds.) Los Angeles, California: University of California Press. END OF FILE