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Remember that even in Quebec, criminal law follows common law. Quebec tends to use civil law for many matters of private law (contracts, wills, real estate deals, etc.), but follows common law in public law matters (criminal, constitutional, some administrative matters, etc.), especially if the matter arises from a federal responsibility under Constitution s. 91. I'll stop there with comments on Quebec's civil law, since I know little about it.
But I would disagree with the "significant differences" between the United States and Canada, as regards common law. Yes, there are differences, but I wouldn't characterize them as significant. Your link is correct, Nat, but those aren't really significant. Yes, Canada has a federal Criminal Code, as does each of the US states, but those 51 bodies have Criminal Codes. Judges are elected in many parts of the US, and are all appointed in Canada, but everywhere in the US and Canada, there are judges. My point is, that even though we may have slight differences, the way we arrive at a conclusion is pretty similar.
"Common law," as it is used and implemented in the United States and Canada goes beyond the stare decisis ("like decides like") doctrine of using precedent cases. It extends to a set of principles that have been used over centuries and have been proven so effective, that they are legally sound. Examples would include the contra proferentem rule in contract law, and the Law of Fixtures in property law. Heck, the Five Elements of Contract must be present in any legal contract, but don't ask me to cite how they came to be. They came to be through hundreds of years of people making deals with each other.
Some common law principles can be traced back to a particular case--Donoghue v. Stevenson established the neighbour principle in tort law, and Carlill v. Carbolic Smoke Ball established principles regarding unilateral contracts. All of these principles, and many others, work in both the United States and Canada. Indeed, when I watch Judge Judy, I can often tell you how Judy is going to decide the matter before her. Why? Because she decides matters based on common law principles--the same principles I learned and use professionally here in Canada.
I'd suggest that the differences are most noticed in our respective vocabularies. In the US, there is a criminal defendant; in Canada, he or she is the accused. An American litigant launches a lawsuit using a Complaint, which will be met with an Answer; a Canadian litigant starts with a Statement of Claim, which will be met by a Statement of Defense. The US has depositions; we have examinations. But in all instances, these are just different words for the same thing. I can read and understand an American Complaint just fine--it may be slightly different in form than the Statement of Claim that I might draft for the same matter, but it serves the same function, and contains the same things I would put in a Statement of Claim.
There's a lot more to common law than I can explain here, as you might expect, but I hope this helps clarify things, Nat.
Once again, thanks Chevy. I was right about one thing, that I should let you explain it
I haven't voted in the poll because I think the UK and the U.S. are quite different from us in different ways and similar in others.
We used to go to the States regularly when a Canadian professor friend teaching there was still alive and were introduced to Americans on a social level. I can only give my impressions and they were that just when you think we're similar, something would pop up that would make me rethink that entirely. The vibe struck me as a lot more aggressive, the people seemed more naive in world their views and I noticed that our friend in spite of efforts in forming relationships with US born Americans, tended to hang out on a regular basis with other immigrants. He himself was an immigrant twice over, having been born in Ukraine and coming to Canada as a refugee as a young boy.
When it comes to the UK my experience is less but they have that lower key vibe that is more comfortable for me and much of it feels very familiar. However, I also felt very comfortable in France when I lived there for a time but never got used to Germany, where I have also lived, which grated on me like fingernails on a blackboard. So I wonder if my comfort with both France and the UK corresponds to the French and English component of Canada.
I've not lived in the US and things observed as a tourist are very different from actually living in a place but on balance, with my love for wide open spaces and a completely different feeling of freedom which the U.S. and Canada share in spite of differences in issues like gun control and health care, I would probably feel more comfortable in the US over the long term than the UK, even though it would take some adjusting.
I've been to New Mexico. Parts of it did seem as though we were in Mexico. It was a long time ago but I remeber stopping at a roadside cafe and no one was speaking English. We came via Durango, Colorado on a twisty road with no guard rails that scared me to death. I did not care for Taos, which surprised me, but did like Santa Fe a lot and would like to spend more time there one day.
It's an interesting conundrum whereas Cloudcroft at 9,700ft elevation doesn't seem to have the predominant Hispanic presence but go down the mountain to Alamagordo, et-voila.....Spanish immersion time again.
BUT, the history of the area precludes thinking this was in any way the result of "illegal" immigration and a negative.
Some similarities to USA but by far more UK in tone...
British form of parliament
Constitutional monarchy
Framework of the rule of law
Commonwealth nation (1 of 53 country membership)
Universal health care
Language (true English word spelling like flavour vs. US's flavor, grammar)
European etiquette practices
Queen on dollars and coin
Peaceful, moderate
I've been to New Mexico. Parts of it did seem as though we were in Mexico. It was a long time ago but I remeber stopping at a roadside cafe and no one was speaking English. We came via Durango, Colorado on a twisty road with no guard rails that scared me to death. I did not care for Taos, which surprised me, but did like Santa Fe a lot and would like to spend more time there one day.
New Mexico is indeed very interesting and at times can feel quite foreign to a Canadian. As can some other parts of the U.S. too.
If we're being perfectly honest, you don't even to have to go much beyond the border to feel like you're in a foreign country. Certainly a place like Detroit right on the border doesn't feel like anywhere in Canada in terms of demographics and socio-economic environment.
Yes really.Zoisite is correct. Check out my other post for a list but just for the sake of being quick..
Constitutional monarchy
British form of parliament
Yes really.Zoisite is correct. Check out my other post for a list but just for the sake of being quick..
Constitutional monarchy
British form of parliament
and several others
The OP said "culturally". Sure, the institutional framework and governance does have an impact on culture to some degree, but still...
Anyway, I guess we'd need to define culture more precisely.
The OP said "culturally". Sure, the institutional framework and governance does have an impact on culture to some degree, but still...
Anyway, I guess we'd need to define culture more precisely.
I divided it into pop culture, and societal/institutional culture.
In other words, why does a Canadian watching an American TV show make them more American, but a Japanese person watching an American TV show doesn't?
Answer. It doesn't.
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I'm not falling for that one. 
