德国和美国作为大陆法系以及英美法系的典型代表,虽然由于法律传统的差异,审前羁押制度不管是在理念上还是具体规定上都有所不同,但是两者对审前羁押都采取严格控制的思路。本文从两国该制度的比较出发,讨论我国审前羁押制度的完善。 Although Germany and the United States, as representatives of the civil law system and the common law systems of the United States and Britain, differ in their legal traditions, the system of pretrial detention differs in both conceptual and specific terms. However, both of them take strict pretrial detention Control ideas. This article from the comparison of the two countries to discuss the system of pretrial detention in our country to improve.