Counterterrorism and the Comparative Law of Investigative Detenti ...

ecole de vérité which extends and enriches the supply of solutions and offers the scholar of critical capacity the opportunity of finding the ‘better solution’ for his time and place.”²⁴

Accordingly, each chapter begins by detailing the experience of the relevant country with terrorism and its legislative response to the threat. It then analyzes the general nature of the criminal justice system of that country, how that country's criminal law defines terrorism, and the country's law of detention, including what provisions exist for investigative detention in standard criminal matters. Thereafter, the chapter analyzes counterterrorism legislation in force and how that legislation augments the ordinary criminal law regime in cases of terrorism. Through an analysis of each country's domestic criminal procedure, this book determines where the U.S. regime of counterterrorism legislation stands in relation to its European counterparts, what lessons―cautionary or otherwise―can be learned from across the Atlantic, and how our domestic policy can be informed by their experience.