Today the United States is the last industrialised country that does not have a comprehensive system for the regulation of dismissals and redundancies. The relative neglect of dismissal protection can be attributed to the union-employer disputes over plant closures and redundancies. Initially US...

This paper analyzes competing models of dismissal regulation from a Law and Economics perspective, using the contemporary US and UK dismissal regimes as a comparative benchmark. The regulation of dismissals in the UK and US differs widely in spite of their joint common-law tradition. Whereas the...