Il grado di colpa punibile. Un'indagine comparata con i sistemi anglosassoni.

Despite it is a subject always "de lege ferenda", the degree of punishable negligence is still one of the issues of contemporary criminal law, even after the recent reforms of medical malpractice's responsibility. The theoretical embrace of criminal negligence with the civil one, makes it necessary to rethink our model based on "simple" negligence. This dissertation, then, starts from the recent italian reforms of medical malpractice's responsibility, which had promised a rethinking of the medical negligence. Then, the discourse moves to the comparison with "common law" legal systems, which have a different type of negligence: "Gross Negligence". This analysis of case law and theory (in particular British, American and New Zealand) is very intersting for the civil lawyer who wants to deal with the degree of punishable negligence.