Drawing on the insights of positive political economy, the authors explicate the ways in which courts uphold these principles in the different systems. Judicial review in the American presidential system suggests lessons for the parliamentary systems in Germany and South Africa, while the experience of parliamentary government yields potential insights into the reform of the American law of lawmaking. Due Process of Lawmaking: The United States, South Africa, Germany, and the European Union with Stefanie Egidy and James Fowkes, 2015