Gerson Trüg
Lösungskonvergenzen trotz Systemdivergenzen im deutschen und US-amerikanischen Strafverfahren
Ein strukturanalytischer Vergleich am Beispiel der Wahrheitserforschung
[Convergent Solutions in the face of Divergent Systems in German and American Criminal Proceedings. A Structural-Analytic Comparison Illustrated by the Process of Ascertaining the Truth.]
2003. 558 pages. Unrevised ebook edition 2025. including VAT
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Although the German and the American criminal procedural systems differ considerably in their dogmatics, both systems have to face similar problems, such as mass criminality and serious offenses. In his work, Gerson Trüg questions whether these problems lead to convergences in the manner in which criminal cases are resolved in Germany and the U.S.A. The three sections into which he has divided his work deal with the discretion involved in deciding whether to prosecute, plea bargaining and the law of criminal evidence, in particular exclusionary rules.