La circolazione dei modelli giuridici in materia di discriminazioni: l’esperienza inglese e la contaminazione tra Europa e Stati uniti

This essay formulates some considerations on the recent expansion of anti-discrimination law, regarding both the development of protection tools and the diffusion as well as the circulation of legal models on a global scale. In the first part of the paper, the focus is on the American experience, as its evolution led to the development of theories, legal issues and solutions. Building on this analysis, the second part of the article shows how the American experience became a “model” for several other judiciary systems around the world. Indeed, while the anti-discrimination paradigm finds its origin in the Anglo-American context, it migrates in the civil law systems throughout the English experience