The UK and US may be two cultures separated by a common language, but they are increasingly linked by issues over access to justice.

That is the clear view of the incoming ABA president, Michael Greco, who, speaking to the Gazette at the conference was adamant that the similarities are striking.


'The same ironies exist in the US as in the UK,' he maintained.


'Both countries have a sufficient number of lawyers, both are rich in resources, and yet both I and [Law Society President] Kevin Martin are trying to mobilise our legal professions to do more public service work.'


Mr Greco &150; a partner at the Boston office of US/UK firm Kirkpatrick & Lockhart Nicholson Graham &150; has more than 30 years' advocacy experience in commercial, employment and property law. One of his main policy objectives for his year in office is to press the US government to create 'a defined right to counsel' in certain civil law cases, such as family, housing and health, where the litigant cannot afford private representation.


It is a bold suggestion that would mirror the position in relation to criminal representation.


'Imprisonment does not have to be behind bars,' explained Mr Greco. 'People can be imprisoned by poverty and discrimination.'


The ABA estimates that 70% to 80% of the legal needs of the poor in the US go unaddressed, which Mr Greco described as being 'totally unacceptable in a democracy'.


Mr Greco's other domestic policy point is to combat recent high-profile attacks on the US judiciary and to raise awareness among the public of the value of the doctrine of separation of powers.


On the thorny issue of practice rights in the US for foreign lawyers, Mr Greco maintained a cautious line.


He re-emphasised the doctrine of states' rights in determining the practice rules in each jurisdiction.


'Unlike other countries where the [legal profession authorities] speak with one voice, in America there are 50 voices. That is the strange and wonderful thing about America - there is this fierce independence that permeates how we do things. We respect the states' rights because they know what works for those states.


'It is a complicated issue. The ABA has had an easier time persuading law firms in jurisdictions such as New York, Chicago, Los Angeles, and Washington DC than we have had in persuading those in other states that it is in their interests to be more welcoming to lawyers from other jurisdictions.'