An ocean of difference between French and US legal systems

PARIS (AP) -- The trans-Atlantic gap separating the U.S. and French justice systems and moral codes is as wide as the ocean itself -- appalling a nation witnessing the unraveling fortunes of a favorite son, jailed IMF chief Dominique Strauss-Kahn.

Some of the charges leveled against Strauss-Kahn in the alleged sexual assault of a hotel maid in New York do not exist in France. And if the case was being heard in France, the 62-year-old IMF chief might risk three to five years in prison instead of scores in the United States, a leading expert says. He also likely wouldn't be sitting in a notorious jail right now on a suicide watch.

Some in the United States, meanwhile, have expressed surprise that French media have identified the alleged victim by name -- nearly unthinkable in U.S. journalistic circles, which avoid publishing a victim's name in suspected sex crimes.

U.S. officialdom is treading cautiously, also: The woman's name isn't even appearing on some New York police documents so as to better safeguard her identity.

The photos of potential French president Strauss-Kahn -- handcuffed, stooped, unshaven, tieless and whisked away to court before photographers -- knocked the breath out of the French public.

The initial response was a collective "that would not happen here."

Not in a country whose laws protect even a petty thief from flashing cameras in a public space and televised court hearings like the one broadcast Monday from Manhattan Criminal Court. Not in a country whose traditions have long shielded the philandering of the powerful, at the risk of failing to uncover travesties of the law.

So different are French laws and mores, it is conceivable that Strauss-Kahn -- innocent or guilty -- failed to grasp the speed by which American justice runs its course, the weight given to alleged sex offenses and the egalitarian premise on which the U.S. judicial system is based until he sat in the infamous Rikers Island prison.

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