[matthewmacleod]

There's actually quite a substantial difference between Scots law versus English and Welsh law in particular! Even disregarding substantial divergence in legislation, Scots law is a mixed civil/common law system, versus the common law system of England and Wales. I'm no US legal expert, but I'd imagine the differences are roughly on par to those found between US states. My understanding is that it's similar to the sort of difference you'd see between Louisiana's system and other states'.

[ElfinTrousers]

TIL. I'd ask now what the difference is between a barrister and a solicitor, but I'm not sure that's a thing an American is even capable of understanding.

[matthewmacleod]

At the simplest level it’s really just the lawyers who operate in the court (barristers) versus those who operate outwith it (solicitors). It’s a bit more complex and couched in tradition but that’s the gist of it. It’s actually from the same etymology as the “Bar” in the US, as in “admission to the bar” or “the bar association”. It represents a person who has “passed the bar” in the courtroom, separating spectators from participants. It’s just that the setup is a little different, with most solicitors not having a right of audience in the court.

Another difference in Scots law - no barristers but “advocates” instead.

[ElfinTrousers]

Thanks, very interesting.