Das US-amerikanische Strafrechtssystem als Modell für die vertikale Kompetenzverteilung im Strafrechtssystem der EU?

Federalization of criminal powers – this so far American phenomenon is now entering the stage also in the EU. Criminal powers which have remained mostly on national level so far are being supranationalized, a system of vertical allocation of powers is emerging and the Treaty of Lisbon provides a proper basis for further intensification of this development. In this situation it would be careless to ignore the vast empirical knowledge of vertical distribution of criminal powers that has been gained in the US during the last two centuries. To benefit from it is the purpose and content of this work. Beginning with a description of the Criminal Law Systems of the US and the EU it develops an answer to the key question to what extent the American system of vertical distribution of criminal powers might be a role model for or a warning to the EU.