Jottings By An Employer's Lawyer

Friday, May 22, 2009

U.S. v. European Labor Model - Time to Reconsider?


I think it will take a lot more than one article from the New York Times to set off much of a discussion on whether or not the European or U.S. labor model is better. Although it might be a more fitting subject for a Labor Day weekend, if you have a few minutes over this three day break, you might read, U.S. Unemployment Rate May Soon Top Europe’s, and give some thought to the differences between the two models.

Those differences go beyond the flexibility inherent in hiring and firing, with the European model being based on more of a human rights notion of fair treatment as opposed to the U.S.'s anti-discrimination model. Although that difference may not always be apparent, in some areas, whether or not to have legislation focusing on bullying behavior in the workplace, for example, the difference is significant, It at least partly explains why such legislation is much more readily received in jurisdictions outside the U.S.


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