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work that is similar in many respects to that of the United States.9 Both countries are predominately English-speaking, common law jurisdictions, and both include one internal unit whose citizens upon joining the federation were Frenchspeaking and whose legal system was civil law.10 This makes both countries a mixed jurisdiction as that term is understood in comparative law.11 However, the roles of the French language and the civil law in Canada are very different from their role in the United States.In Canada, Francophone civilists have a significant presence in the country's national institutions.12 Québec elects seventyfive of three hundred and one members of Parliament, 13 and the last three long-serving Prime Ministers of Canada have been Québec lawyers.14 Francophone civilists are also well represented in the federal civil service, which is responsible for developing legislative proposals and drafting the legislative texts that are submitted to Parliament for enactment.15 Finally, the 9.For example, both are federations established by agreement of former British colonies in which legislative authority is exercised by a central legislature and the legislative assemblies of the constituents; both are electoral democracies; both are founded on British notions parliamentary sovereignty and rule of law; both rely on superior courts to enforce constitutional principles through judicial review.See
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