Livingston et Mignault : voyages civilistes et codificateurs en terres d’Amériques

Abstract

The opening up to foreign legal systems had a strong impact on the 19th century in North America. Pierre-Basile Mignault, the Canadian, and Edward Livingston, the American, were both active travelers and particularly curious about the French and Anglo-Saxon legal traditions. Livingston, through his participation in the drafting of the Louisiana Civil Code and the drafting of his criminal law project, became the paragon of a method, of the civil law codification model adapted to the common law tradition. Mignault, although perfectly mastering both worlds, became the icon of the defense of the integrity of the civil law system in the exercise of jurisprudential interpretation.

Keywords

• louisiana Code
• mixed system
• legal traditions
• codification model
• legal interpretation