d upon the civil law system are France, Germany, Italy, Spain, all of Latin America, and Japan (Meiners, Ringleb, & Edwards, 1994).
According to Meiners, et al (1994, p. 21), civil law is concerned with the "rights and duties that exist among individual society members or between individual society members and the government and other authority in non-criminal matters." More significant in this report is the fact that European civil law differs from common law system in the substantive content of the law, legal terminology, the manner in which authoritative sources of law are identified, the institutional framework within which the law is applied, and the education and structure of the legal profession (Hall, 1992).
In the common law systems, for example, the law of contracts requires consideration for a promise, but consideration has no true analog in civil law. Prior to the statutory reforms in the U.S. in the mid-twentieth century, a seller's warranty had to be expressed in a contract of sale รป it could not be implied. In civil law sy
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