Contrasting Legal Systems

Chapter 5 explores the key differences in the legal philosophies and overall structures of the French and U.S. legal systems, as well as their contrasting approaches to managing potential criminal conduct and apportioning accountability in serious aviation accidents. Specifically, it discusses the steps taken by the French judiciary following the Concorde Flight 4590, Air Inter Flight 148, and Air France 447 accidents, as well as the prosecution of Airbus for bribery schemes aimed at securing and maintaining business. The chapter then examines the actions of the U.S. Department of Justice following the two Boeing 737 MAX 8 crashes and the Alaska Airlines MAX 9 incident, to highlight the differences between the two jurisdictions. The analysis of legal recourse and consequences following aviation accidents reveals several significant differences in prosecuting professionals and corporations involved in aviation accidents, as well as in holding them criminally accountable.