Editing Napoleonic Code (section)

==Codes in other countries==
{{more citations needed section|date=February 2012}}
Even though the Napoleonic Code was [[civil code#Important civil codes|not the first]] civil code, it was the first modern legal code to be widely adopted in Europe, and it influenced the law of many of the countries formed during and after the [[Napoleonic Wars]].<ref name=":0" /><ref name="Robert B. Holtman 1981" /><ref>Senkowska-Gluck, Monika. "Effects of Napoleonic Legislation on the Development of the 19th-century Europe." ''Acta Poloniae Historica'' 38 (1978): 185–198. {{ISSN|0001-6829}}</ref>  In the German regions on the west bank of the Rhine ([[Palatinate (region)|Rhenish Palatinate]] and Prussian [[Rhine Province]]), the former [[Duchy of Berg]] and the [[Grand Duchy of Baden]], the Napoleonic Code was influential until the introduction of the ''[[Bürgerliches Gesetzbuch]]'' in 1900 as the first common civil code for the entire [[German Empire]].<ref name="Arvind TT; Stirton L 2010 1–29">{{cite journal |author1=Arvind TT|author2= Stirton L |title=Explaining the Reception of the Code Napoleon in Germany: a fuzzy-set qualitative comparative analysis |journal=Legal Studies |volume=30 |issue=1 |pages=1–29 |date=March 2010 |doi=10.1111/j.1748-121X.2009.00150.x |s2cid=53581236 |url=http://www3.interscience.wiley.com/journal/123270568/abstract|archive-url=https://archive.today/20130105071047/http://www3.interscience.wiley.com/journal/123270568/abstract|url-status=dead|archive-date=2013-01-05}}</ref>

A number of factors have been shown by Arvind and Stirton to have had a determinative role in the decision by the German states to receive the code, including territorial concerns, Napoleonic control and influence, the strength of central state institutions, a feudal economy and society, rule by [[Liberalism|liberal]] ([[Enlightened absolutism|enlightened despotic]]) rulers, [[nativism (politics)|nativism]] among the governing elites, and popular [[anti-French sentiment]].<ref name="Arvind TT; Stirton L 2010 1–29"/>

A civil code with Napoleonic code influences was also adopted in 1864 in [[United Principalities of Moldavia and Wallachia|Romania]], and remained in force until 2011.<ref>{{cite web | url=http://anndrei.ro/noul-cod-civil-promoveaza-medierea/ | title=Noul Cod civil promovează medierea | date=2013-05-05 | access-date=2013-05-31 | archive-date=2013-07-25 | archive-url=https://web.archive.org/web/20130725045740/http://anndrei.ro/noul-cod-civil-promoveaza-medierea/ | url-status=dead }}</ref>  

The term "Napoleonic Code" is also used to refer to legal codes of other [[jurisdictions]] that are influenced by the ''French Code Napoléon'', especially the ''[[Civil Code of Lower Canada]]'' (replaced in 1994 by the ''[[Civil Code of Quebec]]''), mainly derived from the ''[[Old French law|Coutume de Paris]]'', which the British continued to use in [[Canada]] following the [[Treaty of Paris (1763)|1763 Treaty of Paris]]. However, most of the laws in Latin American countries are not heavily influenced on the Napoleonic Code, as the Spanish and Portuguese versions of the civil code formed the foundation of the Latin American legal systems e.g. the [[Chilean Civil Code|Chilean]], [[Law of Mexico|Mexican]],<ref>[https://www.elsevier.es/en-revista-mexican-law-review-123-articulo-the-need-remove-civil-code-S1870057817300082 The Need to Remove the Civil Code from Mexican Commercial Laws: the Case of "Offers" and "Firm Promises"]; Mexican Law review  Vol. 10. Issue 1, pages 21-44 (July - December 2017)
DOI: 10.22201/iij.24485306e.2017.19.11382</ref> and Puerto Rican civil codes.<ref>{{Citation    |year= 1950 |last=Rabel |first=Ernst   |contribution= Private Laws of Western Civilization: Part II. The French Civil Code  |title=Louisiana Law Review |volume=10  |issue=2 |pages=110   |url=http://digitalcommons.law.lsu.edu/lalrev/vol10/iss2/2/ |access-date= 1 December 2016}}</ref>

In [[Mauritius]], the Civil Code, which originates from the Napoleonic Code, represents an important primary source of law and provides for the rights of individuals, matrimonial regimes, contract law, and property law, amongst others.<ref>{{cite web | url=https://www.mauritiuscounsel.com/mauritian-legal-system/ | title=The Mauritian Legal System | date=January 2018 }}</ref> The French Civil Code was extended to Mauritius under the title ''Code Napoléon'' by decree of [[Charles Mathieu Isidore Decaen]], ''Capitaine-General'', on 21 April 1808.<ref>{{Cite web |title=electronic |url=https://www.ilo.org/dyn/natlex/docs/ELECTRONIC/88152/114145/F-172904586/MUS88152%20Fre.pdf |website=www.ilo.org}}</ref> The Code was modified and embodied in Chapter 179 of the Revised Laws of Mauritius 1945, edited by Sir Charlton Lane, former Chief Justice of Mauritius. The 1808 decree was repealed by Act 9 of 1983, but the Revision of Laws Act which was enacted in 1974, made provision, in section 7, for the publication of the Code under the title "Code Civil Mauricien."<ref>[https://www.ilo.org/dyn/natlex/docs/ELECTRONIC/88152/114145/F-172904586/MUS88152%20Fre.pdf Code Civil Mauricien]</ref>

In the United States, the legal system is largely based on [[English law|English common law]]. But the state of [[Louisiana]] is unique in being strongly influenced by French and Spanish legal traditions in [[Louisiana Civil Code|its civil code]]. Spanish and French colonial forces quarreled over Louisiana during most of the 1700s, with Spain ultimately ceding the territory to France in 1800, which in turn [[Louisiana Purchase|sold the territory to the United States]] in 1803.<ref>{{Cite web|url = http://go.galegroup.com.libezp.lib.lsu.edu/ps/i.do?id=GALE%7CCX3446900575&v=2.1&u=lln_alsu&it=r&p=GVRL&sw=w&asid=be47621d0f52559f686e81e7fc83d650|title = Napoleonic Code|date = 2006|access-date = 17 Feb 2016|website = Gale Virtual Reference Library|publisher = Charles Scribner's Sons|last = Bonfield|first = Lloyd}}</ref> The [[Tenth Amendment to the United States Constitution|10th Amendment]] to the U.S. Constitution grants states control of laws not specifically given to the federal government, so Louisiana's legal system retains many French elements. Examples of the practical legal differences between Louisiana and the other states include the [[Bar examination|bar exam]] and legal standards of practice for attorneys in Louisiana being significantly different from other states; Louisiana is the only U.S. state to practice [[Forced heirship|forced inheritance]] of an estate; additionally, some of Louisiana's laws clash with the [[Uniform Commercial Code]] practiced by the other 49 states.<ref>Engber, Daniel. [http://www.slate.com/articles/news_and_politics/explainer/2005/09/louisianas_napoleon_complex.html Is Louisiana Under Napoleonic Code?] Slate.com, retrieved 11 September 2014</ref>