The French criminal justice system is very different from our own. I have just finished reading Georges Simenon’s Maigret and the Burglar’s Wife [Maigret et la grande perche] (1951); plus I have just recently seen Henri-Georges Clouzot’s film Quai des Orfêvres (1947). In both works, the investigating inspectors give their suspects the third degree. It is a process of intimidating the suspect until he or she talks, no matter how long it takes. In the film, there was a kind of tag team of interrogation, involving Inspector Antoine (Louis Jouvet) and the two detectives above with cigarettes hanging from their lips.

I wonder if things have changed that much in the last seventy years or so. France’s laws are based on the Napoleonic Code of 1804, in which there is a presumption of guilt rather than innocence, as in English Common Law. Suspects could be held in custody for longer periods of time until the evidence was clear.

In the Simenon novel, Inspector Maigret proceeds with the arrest even before this point, because he is so sure that the evidence is forthcoming. In the movie, the suspects, Maurice Martineau and Jenny Lamour, are convinced they will be framed by Inspector Antoine, who actually frees them when he gets a confession (albeit by sustained intimidation) from the real murderer.

It is interesting to see and read about police procedurals from other countries. In the United States, we have adopted English law. I rather suspect that, in the end, both legal systems are equally fair—or unfair.