[funkwyrm]

This is a pretty good paper comparing United States plea bargaining to Germany.

http://digitalcommons.law.yale.edu/cgi/viewcontent.cgi?artic...

[Xylakant]

It's been linked and discussed here http://news.ycombinator.com/item?id=5059044 Please keep in mind that the paper is about as old as I am (34 years) and some things have changed, most notably that germany now has a plea bargaining system, though it's quite a bit different from the american one. See http://www.concurringopinions.com/archives/2009/07/german-bu... for an overview (linked from the discussion).