Abstract

The numerous and diverse ways in which the form of a federal state can be structured are highlighted by a comparative study of the Canadian and American constitutional models, also taking account of the influence of political-economic events originating from the social and economic characteristics of the two countries. The essay starts from a historical perspective, assessing the extent to which the Constitution of the United States was a significant model in the debate that gave rise to the British North America Act of 1867, and then the extent to which the Bill of Rights and American constitutional jurisprudence influenced the Canadian Charter of Rights and Freedoms and the work of the Supreme Court. In both cases, as well as similarities and differences, the essay emphasises the difficulty of striking an institutional balance between central power and local powers.