The separation of powers in civil law countries

My paper will discuss how the separation of powers, as understood in civil law countries, proved ineffective in protecting liberty. I will argue that it has been quietly replaced by what Americans consider a system of checks and balances. I will argue that checks and balances are needed because as Lord Acton put it “Power corrupts; and absolute power corrupts absolutely. I will discuss the regimes in Germany; France; Italy; Brazil; Mexico; South Korea; and Indonesia.