Hacker Newsnew | past | comments | ask | show | jobs | submitlogin

Yeah, the whole concept of rights in the US are, in the main, about restricting what the federal government and states can do individuals.

Whereas in Europe our concept of rights include restrictions on the state, but also also might restrict non-state actors. We also have a broader concept of rights that create obligations on the state and private actors to do things for individuals to their benefit.



It’s kinda good the planet gets to run both experiments, and more.

The EU approach seems to want to insert government in to contracts between private individual and those they do business with, and the US approach seems to want to maybe allow too much power to accumulate in those who wield the mercantile powers.

The optimal approach probably lies in the tension between multiple loci.


It's one experiment because both systems are competing at the same time for global resources both in cooperation and competition with each other and other actors. Additional both systems exist in such widely different contexts that any comparison would be inaccurate because other factors such as geographic and historical have a large impact on any measured results.


The US approach is more than that, for instance if every employee in a business pushes for a contract that says workers will negotiate as a block and pay new union dues, and the contract says new hires will be bound by that too, that's illegal in many states. Not just the normal "right-to-work" restrictions, the contract isn't valid even if unanimously agreed on by every current employee (union security agreements). But for shareholders they all set it up like that, with votes weighted by dollars. A new shareholder can't buy someone's shares and government says it's illegal for him to be bound by the voting structure.

And secondary strikes are also illegal in the US under Taft-Hartley.


The optimal approach appears domain specific and granular, too.

As for domain specificity:

I don't know any Europeans who'd prefer to have American healthcare.

I don't know any European technology companies that hold a candle to the sheer breadth and depth of capabilities brought into the world by Google, Apple, Microsoft, Amazon, Nvidia, AMD, Intel, OpenAI, or Anthropic.

Yes, Mistral, Nokia, OVH, and SAP exist, but compared to the alternarives, they exist in the way the American healthcare system exists compared to its alternatives.

As for granularity:

Perhaps we want American style governance for building the tech, but then European style governance for running it?


The American model of governance was created for a world with very distant nation-state threats but a large number of colonial threats, which is why it's centered around "every man for themselves" (in spite of FDR's best efforts). On the contrary, European governance was basically developed during the Revolutionary Wave, which was sweeping all across Europe, that monarchies found that the only way to appease the people was to give into their reforms - and often rapidly because of the domino effects of revolutions. In other words, American governance was built from the ground up, while European governance had to be adjusted within the existing environment and monarchical government frameworks.

In fact, European governments weren't even well-defined in their current state up until the end of WW2, in spite of how much Europeans like to take potshots against USA for being a "young" nation.

This does make the American form great for working with uncharted territory (how to handle new tech, how to exploit the earth in new ways, etc.) while the European form is more reactionary (how do we keep the people appeased, how do we provide a better standard of living, how do we alleviate hardship).

Perhaps the ideal mix of the two, between the frontier-style governance and European-style reactionism, like the Swiss model.


> I don't know any Europeans who'd prefer to have American healthcare.

Selfishly I think my American healthcare is better than anything I ever had in the UK. I can see a doctor within 2 weeks even a specialist, I can actually get a sleep study, my doctor will actually listen to me rather than tell me I'm just getting old, go home and take an ibuprofen.


In terms of health outcomes, the UK generally has higher life expectancy and lower maternal mortality rates than the US - but that said, even the richest Americans face shorter lifespans than their European counterparts.

The real focus and point of contention should be that the US healthcare system is exponentially more expensive per capita than any European model, but is worse for almost all health outcomes including the major litmus tests of life expectancy and infant mortality. In some cases, the wealthiest Americans have survival rates on par with the poorest Europeans in western parts of Europe such as Germany, France and the Netherlands.

https://www.brown.edu/news/2025-04-02/wealth-mortality-gap

Americans average spend on inpatient and outpatient care was $8,353 per person vs $3,636 in peer countries - but this higher spending on providers is driven by higher prices rather than higher utilization of care. Pretty much all other insights in comparing the two systems can be extrapolated from that fact alone imo.

https://www.kff.org/global-health-policy/health-policy-101-i...


This is probably incredibly naive so apologies if so - are things like differing obesity or other health problem causing conditions accounted for when looking at overall outcomes of the system?

The higher cost makes perfect sense to me but calculating an apples to apples comparison of health outcomes between potentially very different populations seems potentially very difficult? Again sorry it's probably a solved problem but figured I'd ask :)


The lower life expectancy in the US is almost entirely down to young people dying at a much higher rate than Europe due to car accidents, murder, and drug overdoses. It skews the averages pretty badly. If those individual risks don't apply to you then life expectancy is actually pretty decent.

There is a wide variance in the general healthiness of the population depending on where you live in the US, which does affect life expectancy. Where I live in the US my life expectancy is in the mid-80s despite the number of young people that die.


That's because mortality rates are only weakly correlated with healthcare quality. The US has much higher death rates in some young demographics, which skews the average, but those people didn't die due to lack of medical care.

You can have exceptional healthcare quality and relatively low life expectancy in the same population.


The Brown study I cited above concludes differently, and is strictly a longitudinal, retrospective cohort study involving adults 50 to 85 years of age.

https://www.nejm.org/doi/full/10.1056/NEJMsa2408259

Within that 50-85 cohort, among 73,838 adults (mean [±SD] age, 65±9.8 years), the participants in the top wealth quartiles in northern and western Europe and southern Europe appeared to be higher than that among the wealthiest Americans. Survival in the wealthiest U.S. quartile appeared to be similar to that in the poorest quartile in northern and western Europe.


specialists in two weeks is definitely not the norm everywhere in the US. it's certainly not in Seattle.


This is likely very regional. As a single data point, raising the family in the Boston area for the last 25 years I do not recall not being able to see a doctor the same day for the regular scares, from ear pains and high fever to falling and later vomiting (is this a concussion?).

A few times when we needed to see specialists, we often saw them within 24 hours; occasionally longer but I would say with a median of 48-72 hours. Even things that are clearly not urgent (for dermatologist "hey, I have forgotten about skin checks for the last 2 years, can we do the next one now", for ENT "hey, my son is getting nosebleeds during high intensity sports; can you check if there is a specific blood vessel that is causing problems"?) always happened well within two weeks. Three caveats to this happy story:

1. This is Boston area with likely the highest concentration of medical practitioners of all kinds in the US. I had good insurance with a large network, decent out-of-network coverage and for most cases not needed a pre-approval to see a specialist.

2. Everyone is generally healthy and our "specialist needs" were likely well trodden paths with many available specialists.

3. Our usage of the doctors, as the kids became generally healthy teenagers and adults, dropped significantly in the last 5-7 years. I hear post-covid the situation is changing and I may be heavily skewing to the earlier period.


At least from what I can see, COVID and the changes in attitudes towards medical professionals are driving a lot of burnout and leaving the profession; and since then economic pressures are squeezing private practices out of existence and a lot of specialists end up working for private equity now.


I think you should also balance your take by asking people who recently lost their job what they think about their healthcare. I’m sure you’re aware of that, and my point is rhetorical, but that’s the trade off here, it isn’t only about what it looks like when things go right, you should also consider what happens when things go wrong. It’s also enlightening to see what happens many times when people “did everything right” and still got shafted by the US system. See: Sicko for instance https://m.youtube.com/watch?v=YbEQ7acb0IE


I suspect the time it takes to see a specialist in the UK depends on how urgently the issue needs to be addressed. The real advantage you have is that you can be seen by a specialist within two weeks even for non-urgent stuff. That’s not to dismiss your need though. The definition of medical urgency and comfort don’t align well.


The US has world-class healthcare, if you can pay for it. If you can't, then you're getting the healthcare equivalent to a third-world country.


That's ridiculous. Nobody gets healthcare equivalent to a third world country unless they just don't try. (Think, an addict or mentally ill person, which is still not a good thing, but much smaller of a carve-out than you've represented)


You can and get that in the UK, surely?


If you cough up for private healthcare maybe, when it comes to the NHS if it's not going to kill you immediately it's more or less 'take a spot in the waiting list and God will sort it out' these days.


Most UK healthcare these days is someone tells you to take a paracetamol over the phone. Even dentists...


That's largely due to austerity effects and not the inherent model of UK healthcare. That's what happens when political appointees and ministers bully civil servants and doctors that the best minds all leave, while the government significantly cuts funding to the NHS while forcing it to move to AWS.


> I don't know any Europeans who'd prefer to have American healthcare.

Probably depends a lot on where you are in Europe. Some countries have long waiting lists for surgeries (life saving ones) and access to doctors is very limited (too few, months to get an appointment) so it sucks as well if you are in such a situation


Here in America we have to wait months for the privilege of paying out the nose.


>I don't know any Europeans who'd prefer to have American healthcare.

Some 50-100k Europeans fly to the US to get American healthcare every year.


Ok, so about 0.0134%, Parent comment’s point is that -the average European- absolutely does not want the US healthcare system in Europe. Simply due to our shared believe healthcare is a basic right and should be universally available to everyone.

Those who have the financial means to travel to the USA for medical treatment do so largely due to running out of conventional options at home, experimental treatments or specific doctors who are regarded as the best in their particular field.

Most of the US outbound medical travel is due to treatment at home being too expensive and risking pushing entire families to bankruptcy.

The fact that 100k europeans fly to the US for medical treatment is factual, but does not equal them wanting the US healthcare system in Europe.


That's about how many need it, can afford it, and can't wait for an appointment in half a year.


Idk .. I injured my knee playing soccer (tore a bunch of ligaments) a few months ago. Wasn't life threatening. Still, got care after waiting for about an hour, xray and all. On a Saturday. In Sweden, single payer insurance. I paid only about $20 out of pocket.


Just as a contrasting data point, some estimates are that well over a million Americans travel overseas for medical care every year.

https://www.amjmed.com/article/S0002-9343%2818%2930620-X/ful...

This is mostly to obtain cheaper care. In general America does seem to have some of the best care in terms of quality. It’s just also some of the least affordable.


US is not the only destination for Europeans, they also go to Thailand and wherever. Few Americans go to Europe. It's not affordable, but when money is not the issue you go to the US.


i'm one of the Americans. went to South america for a dental procedure that was 12k in the US, 2.5k there. very modern facilities, they had some better tech than my american dentist. if you can speak a bit of spanish, i highly recommend looking into it for expensive dental stuff.


So the other 99.987% of Europeans agree with the parent comment?


No, they just can’t afford it or don’t need it.


Most people prefer healthcare they afford over healthcare they can’t. (Most, not all. There are a surprisingly large chunk of Americans who seem to vote Against their best interests in a lot of areas.)


I would argue that "don't need it" could just as easily be because they have better healthcare closer to home.


I couldn't find a source for this with a quick couple of searches, could you provide one?


I'm not GP, but https://www.trade.gov/survey-international-air-travelers-sia... suggests that in 2024 about 0.4% of European travellers to the US told the government they were coming to receive medical treatment, and https://www.trade.gov/feature-article/december-and-annual-20... says about 13 million people from Western Europe visited the US in 2024, and if you multiply those numbers you get 50k.


That isn’t the flex you think it is lol


I don’t want to rain on your parade, but you would be more fair by replacing these companies with VCs, because they’re the ones lifting real weight here.


That's because in the US we don't give non-state organization power over other people. At least not in the European way where you have to give your life to an org. A US citizen has the freedom to disassociate with any organization at any time for any reason.

Of course this comes with a social cost, offset as this allows people who are discontent with their arrangements to forge a new path States like California have high job lock, so most innovation comes from side-projects as people checkout from work.


> That's because in the US we don't give non-state organization power over other people.

How are credit ratings maintained again?

> At least not in the European way where you have to give your life to an org.

I have to what!? News to me.

> A US citizen has the freedom to disassociate with any organization at any time for any reason.

Maybe, but the EU is more militant in enforcing that right. Some US states are working on "right to be forgotten" laws, but they've got a lot of catching up to do, and I don't think there's a federal law in the works yet.


> That's because in the US we don't give non-state organization power over other people

Have you been following the news for the last few years?


>in the US we don't give non-state organization power over other people.

False.


What are you on about?


What restrictions do European governments impose on the state?


I don't agree with that at all. If anyone else tries to infringe your rights it's either voluntary i.e. you've consented to this, or it's involuntary in which case you can sue them or the state will prosecute them on your behalf.


What you’re missing is that the set of rights European countries recognize and the set of rights that the American government recognizes are not the same set.

In Europe they recognize a right to be forgotten that simply does not exist in the US. Europe recognizes personal data rights that the US does not. These data rights impose requirements on the way companies manage your data and specifically do not allow, e.g., Facebook to get you to consent that your rights do not apply. The European government protects imposes citizens’ rights on businesses in several ways that the US government does not.

On the other hand, US free speech rights are generally stronger. And of course no one else except US citizens have an inalienable right to sleep on a bed made of loaded handguns.


Obviously the rights that the state grants are different in the US than Europe, but the rights of individuals are protected versus other individuals, corporations, and general organisations; just as they are in all civilised countries. To the extent you can have famous cases where people sue large coffee franchises for selling coffee that's too hot.

So the statement that "the whole concept of rights in the US are, in the main, about restricting what the federal government and states can do individuals" is far from reality, and I felt it necessary to ground this conversation back in reality.


> but the rights of individuals are protected versus other individuals, corporations, and general organisations; just as they are in all civilised countries

Kind of. In the US there is no protection of free speech when posting in Twitter or Facebook, for example. There isn’t even a consent issue here. There’s no need for you to consent that Facebook can sensor your speech because you have no right to free speech in that context at all.

This is exactly what the poster was presumably referring to. Many rights in the us are in fact only protected from infringement by the government.


Unfortunately, the world contains nuance that your statement does not.


What I said is a very general statement that broadly applies to all civilised countries, reiterated because the parent comment was very incorrect suggesting that rights are mainly protecting citizens from their state in the US. It's simply not true.


It is oddly funny that people in my town are ferociously protesting the police force's adoption of Flock surveillance cameras when everyone already carries total surveillance devices (smartphones) on their person at all times.


You can (generally) tell when a person around you is filming, and you generally don’t have to worry about tons of random individuals bringing together footage of you for tracking and surveillance.


Private individuals generally aren't systematically using their cameras for mass surveillance of you. The government is.


> The government is.

Companies too.


Companies can't use violence against individuals who do things they don't like.


Most of the cameras are attached to either Apple or Android devices. The companies that control these ecosystems could use them for mass surveillance. The government could 'politely' ask these companies to do that for them. Or they could just directly order the phones.


Sort of except for the fatal flaw that you are talking about battery powered devices that mostly live in peoples' pockets. The reason Flock cameras and Ring doorbells both serve well for mass video surveillance is consistent predictable location and power.


Maybe, yes. On the other hand, there's lots and lots of people running around with these things, so you get pretty good statistical coverage, especially in cities.


Could, but don't.


You really think Google and Apple aren’t tracking users?


No, I really don't think Google and Apple are using Android/iPhone cameras or microphones for mass surveillance.


Unless we are trying to do the "conspiracy theory" route: there is not "thinking" here. You can at least sniff traffic or whatever and tell if your phone is ringing back to google even when you tell it not to.

And the discussion above is about a different kind of surveillance. Notifying Google (or state) that I'm sitting in front of my PC is one thing. Sending photos of videos of me jerking off is different.


In Germany it's (very roughly speaking) illegal to film people in public. (Importantly, not the same as filming a thing or event and having people incidentally in the frame)


I can leave my phone at home. I cannot leave flock at home. It’s about consent.


I'm pretty sure the point parent was trying to make is that you can't get other people to leave their phones at home and there is very little recourse if a private citizen decides to record you without your consent from their phone in a public space. There's of course a difference in the powers involved, but people have had their lives ruined because somebody captured a video of them out of context or in their worst moment.




Guidelines | FAQ | Lists | API | Security | Legal | Apply to YC | Contact

Search: