우리 대법원 판례에 대한 미국 연방법원 판례의 영향에 관한 비교법 연구 = Comparative Legal Research on the Impact of Decisions of the U.S. Federal Court on Those of the Supreme Court of Korea

다국어 초록 (Multilingual Abstract)

Among legal systems in the world, consisting of mostly civil law system and common law system, Korean legal system belongs to the civil law system. Since late 1990s, however, Korean legal system has been strongly influenced by Anglo-American legal system, a representative of common law system. After brief comparison of the characteristics of common law and civil law system, this thesis analyzed several recent decisions of the Supreme Court of Korea, and compared them to those of federal courts of United States. While recent decisions in the areas of antitrust law, civil procedure and tax law have similarity, those in the areas of criminal procedure and labor law demonstrate results of applying distinctive rules of respective country. The comparative legal analysis between the decisions of both Korea and the U.S. indicates that decisions from one country has impact on those from the other country although the countries belong to different legal system. This research sheds light on the necessity of further in-depth comparative legal research in Anglo-American law.