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I'm not sure what paper you're reading either.

Page 210: "Plea bargaining has been documented in Eng- land where crime rates are closer to German than to American levels; the constant factor in both England and the United States is, of course, adversary criminal procedure."

All that's talked about on page 215 is that "in contemporary [1979] England, official ideology has been until lately loath to acknowledge the existence of plea bargaining," but that it is in fact well-documented (as an example showing that, if there were an unofficial plea bargaining system in Germany, it would be easy to discover by interviews of legal counsel).

I agree that the US is indeed a more extreme case (especially in not limiting plea bargaining to certain types of cases and openly accepting plea bargaining in principle), but this author clearly believes that the causative factor in both cases is the complexity of common law trial procedure (which, again, seems to have reached extremes in the US that are unmatched in the UK).



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