part vi • european legal integration • pia letto-vanamo ditionally, it is too narrow to speak only of private law. Developments and trends in public law need to be considered, too. Similarly, the interplay of supranational or transnational regulation on the one hand and national regulation on the other should be recognized, as should the impact of international and European ideas on national scholarly debate. It is not only European institutions such as the Council of Europe, the European Court of Human Rights, the Venice Commission (the European Commission for Democracy through Law) or the EU institutions that play an important role in furthering legal Europeanization. There are also features within national legal systems that assist legal harmonization. These even suggest something that could be termed a European legal culture. I learnt this when teaching European exchange students in Helsinki. Two facts regularly surprise students taking a comparative course on ‘Nordic Law in the European Context’: Nordic countries are countries without civil codes and without constitutional courts. In fact, there have been two big legal movements since the 1990s, since the collapse of the Soviet Bloc. The one has been towards a (national) civil code; the other towards constitutional review by a special court. At the moment, the great majority of European countries have a constitutional court. And – speaking of legal culture – these countries not only have acourt, but they also have judges who are well networked with other constitutional courts both Europe-wide and globally. The structural difference between the main models of constitutional review – between the USmodel and the European model of constitutional courts – is well known. Each model has its own history. The history of the first is largely linked to the US Supreme Court caseMarbury vMadison of 1803; the characteristics of the second have their origin in the Austrian Constitutional Court (Verfassungsgerichtshof) of 1920, although the majority of constitutional courts were established in the second half of the twentieth century. The European courts cannot be separated from the fundamental political changes in the countries concerned.5 Actually, there are three generations of courts, all born of a so-called system change. 5 For a brief overview, see Giuliano Amato & Benedetta Barbisan, Corte Costituzionale e Corti Europee: Fra diversità nazionali e visione commune (Bologna: Il Mulino, 2015). 280
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