A Comparison of Drug Laws in France, UK, and US
Drug laws in France, the United Kingdom, and the United States have varied historical backgrounds and approaches, leading to different policies, punishments, and enforcement methods. From the implementation of the Misuse of Drugs Act in the UK to initiatives like drug courts and sentencing reforms in the US, each country's approach reflects a unique perspective on combating drug use and crime.
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Drug Law: A Comparison of the France, the United Kingdom, and the United States Alina Fitzner
Introduction Drug use documented as far back as Ancient Egypt12 United States, the United Kingdom, and France Different methods of categorizing drugs Enact different punishments for drug crimes Enforce compliance in different ways
Drug Law History Ronald Reagan: Governments exist to protect us from each other. We can t afford the government it would take to protect us from ourselves. 15
The United States - Policies 1968 - Total War 3 1970 - Controlled Substance Act 3 1973 - Era of Rockefeller 10 1986 - Sentencing Reform Act 1986 - Anti-Drug Abuse Act 1988 - Anti-Drug Abuse Act
The United States - Results 1980 - 15 people per 100,000 adults in prison for drug crimes 4 1997 - 148 per 100,000 4 2013 - ~ federal inmates were drug convictions 4
The United States - Reforms 1989 - 1st drug court in Dade county, Miami13 2008 - Second Chance Act4 2009 - Reform of Rockefeller-era drug laws4 2010 - Fair Sentencing Act2,4
The United States has the highest incarceration rate in the world More than 700 out of every 100,000 Americans are incarcerated4 Rate 5x the international average4 Comparison: France s rate is 96 per every 100,000 citizens4
The United Kingdom - Misuse of Drugs Act Implemented in 19712,16 Restricts importation, exportation, manufacturing, supplying, and possession of drugs2 Classified drugs:16 o Class A: Heroin, Cocaine, Morphine, Opium o Class B: Amphetamines, Barbiturates, Cannabis o Class C: Benzodiazepines, Anabolic Steroids
The United Kingdom - Policy Developments Street Warnings 1998 - Crime and Disorder Act Criminal Justice Act of 2003 2010 - War on Drugs
France Drug abuse is a sickness, not just a crime8 Enforces total prohibition8 2000 - 3% crimes were drug crimes1 o 88% were cannabis related1 o 74% arrested were users only 13% were dealers1 25% of 17 year olds use cannabis17
France - Treatment Programs Multiple programs exist Treatment is not easily available8 Only 5% of prosecuted addicts follow through with treatment8
Comparisons All three take a turn for the more severe in the 1970s o Developed minimum sentences The United Kingdom has more public involvement in policy development Each country has a different drug focus o The United States: Cocaine o The United Kingdom: Heroin o France: Cannabis
Cannabis Legalization - open legal market Decriminalization - removing or lessening legal penalties, despite the continued illegality Prohibition - enforcement of criminal laws and restrictions
Cannabis - The United States Push for legalization Legalized - Washington and Colorado Medical Marijuana legal in 18 states Largely decriminalized
Cannabis - The United Kingdom Focus of enforcement in 1970s o 70 - 80% of drug offences16 Lambeth Cannabis Warning Pilot Scheme16 o Step towards decriminalization o 59% police surveyed disagreed o 41% believed juveniles should be charged as adults
Cannabis - France Strictest enforcement against cannabis9 Use equals up to one year in jail and 3,750 euro fine9 Making or transporting results in prison and 7,500,000 euro fine9 Medical marijuana is forbidden9
Drug Treatment - The United States Addiction is a largely neglected issue Alternatives to prison4 o Drug courts, work programs, treatment and intervention programs o Disease model of addiction Second Chance Act 20084 Treatment includes mandatory testing and aftercare
Drug Treatment - The United Kingdom Multi-pronged approach: individual and family psychological treatments and physical treatment5 Programs limited to the clinically dependent Cognitive Behavioral Therapy, Alcoholics Anonymous, and Narcotics Anonymous5
Drug Treatment - France Sick first, criminal second o Addicts can have treatment instead of prison Restrictions on treatment make options limited o Only addicts qualify for treatment o Cannabis users and occasional users are excluded o Dealers are not eligible for treatment Only 5% of addicts prosecuted finish treatment
Methadone Treatment Specific for heroin addiction Recognized by United States Institute of Medicine and World Health Organization6 Limited access6, 18 o Not covered by insurance o Ingestion often must be observed o Waiting lists months long
Conclusion Drug crime is a universal problem Each country faces problems differently All countries have similar cycles o Limited enforcement o Increased enforcement beginning in the 1970s o Implementation of moderation Further research: limitations, effectiveness, improvements
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