> I recommend reading this paper about the differences in Administrative Procedure legislation (which includes federal employment rules and norms) in Germany versus the US [0]
No, administrative procedure law (US APA, German VwVfG) is not the primary legal regime for government employees, they are governed by civil service law (e.g. the Bundesbeamtengesetz in Germany, Title 5 of the United States Code).
> In general, I think online Europeans need to stop comparing the US to their countries. The causes for our dysfunctions are different, and our entire legal, constitutional, and political traditions are VERY different because of a 300-500 year split.
The common law tradition, followed by the US and Canada, originates in Europe (England); among EU member states, Ireland’s legal system is completely based on common law, while Malta has a mixed legal system which combines Roman/French and English legal traditions. Such a mix is not unique to Malta, you can find a similar mix in Louisiana, Quebec, Scotland. Cyprus’ legal system is heavily based on English common law, but also with Ottoman and French influences (the French influence comes via Greece, since modern Greek law was modelled off France)
In terms of political systems, Canada and Germany have a lot in common, both being parliamentary federations - yes one is a constitutional republic the other a monarchy, but that makes little difference in practice. The presidential system used in the US, while common in Latin America, is basically unheard of in Europe; although, the semipresidential system used in France can be viewed as a hybrid between an American-style presidential system and the parliamentary system which is the European norm
So I think North Americans and Europeans have more in common in terms of political and legal traditions than you acknowledge