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Hugo

Raised in South Africa. Educated in North America. Excited about building bridges and experimenting @Xfund

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“European privacy norms are founded on French and German ideas of “personal honor.” Continental “privacy,” like continental sexual harassment law, prison law, and many other bodies of law, aims to protect the “personal honor” of ordinary French and German folk. American law takes a very different approach, protecting primarily a liberty interest. The Article traces the roots of French and German attitudes over the last couple of centuries, highlighting the French experience of sexual license in the nineteenth century and the German experience of Nazism. The Article then discusses the current state of French and German law with regard to matters such as consumer credit reporting, public nudity, and the law of baby names. It contrasts continental approaches to what we find in American law. Throughout, the Article argues, American law shows a far greater sensitivity to intrusions on the part of the state, while continental law shows a far greater sensitivity to the protection of one’s public face.”