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What do Brexit and Hong Kong separatism have in common? They are the latest manifestations of the deep, centuries-long separation between common law and Roman (civil) law.
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The EU and the Chinese Communist government operate under the civil law tradition, which included Prussian Law and the Code Napoleon. It originates in Roman imperial law, which included the maxim "the emperor's will is law."
British and Hong Kong law are based on the English common law system, where more of the law has been based on judicial precedent than the more legislatively-centered civil law countries.
The great dictators of the 20th century -- Lenin, Stalin, Mussolini, Hitler, Franco, Mao, Peron, Pinochet, Castro, Pol Pot, and Maduro among others -- all rose and thrived in the civil law system ultimately derived from imperial Rome.
The U.S. is a mostly common law jurisdiction, consistent with some Hong Kong protestors flying American flags. The Brexit & HK struggles are both efforts to, among other things, preserve & protect islands of the common law tradition from encroachments of the civil law system.
