In the mind of an English or American lawyer a taste and a reverence for what is old is almost always united to a love of regular and lawful proceedings.
This predisposition has another effect upon the character of the legal profession and upon the general course of society.

The English and American lawyers investigate what has been done; the French advocate inquires what should have been done; the former produce precedents, the latter reasons.

A French observer is surprised to hear how often an English dr an American lawyer quotes the opinions of others, and how little he alludes to his own; whilst the reverse occurs in France.

There the most trifling litigation is never conducted without the introduction of an entire system of ideas peculiar to the counsel employed; and the fundamental principles of law are discussed in order to obtain a perch of land by the decision of the court.

This abnegation of his own opinion, and this implicit deference to the opinion of his forefathers, which are common to the English and American lawyer, this subjection of thought which he is obliged to profess, necessarily give him more timid habits and more sluggish inclinations in England and America than in France.
The French codes are often difficult of comprehension, but they can be read by every one; nothing, on the other hand, can be more impenetrable to the uninitiated than a legislation founded upon precedents.