In Britain, lawmakers can be suspended for accusing others of lying (AP)

http://news.yahoo.com/s/ap/heckling_history

Sep 11, 2009
Heckling of president is rare in American history
By JOCELYN NOVECK, AP National Writer

...There's little if any historical precedent for a U.S. congressman individually challenging a president during a speech to Congress — let alone accusing him of lying — which is just one reason why some longtime political observers were stunned by Rep. Joe Wilson's outburst. Presidents didn't even address Congress between 1800, when John Adams held the job, and 1913, says Fred Beuttler, deputy historian at the House of Representatives, who calls the Wilson incident "highly unusual, if not unique."...

Some have compared Wilson's outburst to those that occur routinely in Britain's House of Commons, when the prime minister is answering questions. But one political analyst says this is vastly different, because the prime minister isn't the head of state. "Our president is the head of government and also the head of state, the combination of the country and the government," says Steven Cohen, professor of public administration at Columbia University. "We expect a certain amount of deference to the president, in the same way as we would for the queen. Here, we combine the two roles."

To another political analyst, it's the nature of the accusation — an elected official calling the president a liar — that is not only a serious breach (accusations of lying are forbidden under House rules) but also extremely rare in politics. "Accusing someone of lying is impugning their integrity," says Kathleen Hall Jamieson, an expert on political communication at the Annenberg Public Policy Center at the University of Pennsylvania. "It was done in print a lot in the 19th century. But it is not routinely done in political discourse." Congress is a place of deliberation, Jamieson adds: "If you call someone a liar, you've ended the deliberations. This is such a strong norm that it's been in the House rules since Jefferson."

In Britain, too, despite its lively parliament sessions, lawmakers can be suspended for accusing others of lying. One, Tam Dalyell, was thrown out for doing just that to former Prime Minister Margaret Thatcher, whom he called "a bounder, a liar, a deceiver, a cheat and a crook." A British lawmaker was rebuked in 1986 for referring to President Ronald Reagan as Thatcher's "cretinous friend."... And royalty hasn't been exempt: The late Willie Hamilton, a Labour MP, was ordered to retract his description of Prince Charles as "that young twerp."

a lot of "europe is always better" people here fail to realize the extent of our civil liberties, when compared to the UK etc.

i like britain's loser pays system, but you are aware that in the uK you have no right to remain silent (it can be used against you) and there is no automatic exclusion rule like we have on illegally obtained evidence.

they also have broader search and seizure powers in general.

i do like the wigs though

when will you the "america is always best" crowd at least BOTHER to check facts :






http://en.wikipedia.org/wiki/Right_to_remain_silent

your statement is exactly the same BS heard about "presumption of innocence", search and seizures etc...

regarding illegally obtained evidence, the current US procedures of "framing" somebody are completely illegal in most European countries

shall we discuss wiretapping ?

Do you understand why Europeans are sick and tired of hearing that lecturing from people who don't have a clue about what is REALLY going on in Europe and at the same time are claiming to possess civil liberties that don't really exist to the extent they are claimed to be ?

American exceptionalism is dead. Get over it.

i quote

"There may be no conviction based wholly on silence.<2> Where inferences may be drawn from silence, the court must direct the jury as to the limits to the inferences which may properly be drawn from silence.<3>"

"This does not apply to investigations by the Serious Fraud Office, where there is no right to silence."

QED my man!

again, in a US court of law, it can't even be PRESENTED to the jury that you chose to remain silent.

in england, as your quote proves, it CAN be considered at trial, it's just that no conviction based WHOLLY on silence can be made.
IOW, in the US, as i said, silence cannot be used against you.

in the UK, it CAN. it's just clear that there are limits to which it can be. duh. there are limits to every form of evidence, direct, testimonial, etc.

again, major DUH

in the US, no conviction even based solely on a FULL confession can be made. there STILL has to be corpus delicti.

iow, EPIC FAIL

EPIC

thanks for citing the relevant that PROVES my point.

oh, you also fail on the strawman account.

i never said the US system was the BEST. i said that it was not true that the british system was the best

those are not equivalent statements. i think in SOME respects, the US system is the best, in others, the UK system is the best.

it also depends on "best for what". if you are talking "best" for the side of the state being able to present questionably obtained evidence, the UK clearly wins. however, at least from a defense attorney standpoint, that would not be THE BEST

i do think their tort system is superior, though. loser pays.

so, that's TWO epic fails in one post.

you rawk!

Thatcher was "a bounder, a liar, a deceiver, a cheat and a crook."

And Reagan was her "cretinous friend."

That's one of the big reasons why the credibility of UK politics is at such a low at present.