1. Proskauer New Member

    Living in France, speaking English
    I understand that avocat means lawyer. But as a non-lawyer I'm not sure if there's an equivalent to the French title. Lawyer-at-court? Lawyers go to court, normale. Lawyer-at-the-bar? Can anyone help me please? C'est pas evident!
  2. hunternet

    hunternet Senior Member

    France - French
    maybe "barrister" ? But the titles and trades are completely different. You may keep "avocat à la cour" and explain the whole thing in English.
  3. villefranche Senior Member

    Perhaps "trial lawyer."
  4. edwingill Senior Member

    England English
    barrister in the UK trial lawyer in the USA
  5. keumar83 Senior Member

    attorney-at-law ?
  6. didibule New Member

    Lawyer at court
  7. Jiminthesun New Member

    The Francophone system is different from the UK or US. So there is no real translation. To become an Avocat in France its necessary to do a masters in law and then pass one Bar exam. You then complete 2 years training and take a second bar exam to achieve the status of Avocat à la cour which which means you can then represent clients in front of a Judge.
  8. Lex est quod notamus

    Lex est quod notamus Member

    English - USA
    Even if there is no exact equivalent (there rarely is), it's important to find a translation because in some contexts you can't just leave the original term.

    Given the definition, attorney-at-law works well for the US in all contexts, and barrister (or sometimes solicitor advocate for lower courts, or come to think of it advocate by itself) would be solid translations for this. It all depends on the target audience.
  9. Phil512

    Phil512 Senior Member

    Français - Belgique
    For the record, and against the language pollution that some translated TV--series and movies spread all over the world, in the so-called Napoleon law system (in France and Belgium, certainly), you have to be a lawyer (= "juriste", which means you have graduated in law from the University) to possibly become an "avocat" and then be allowed go to court (see above). There are requirements to fulfill (bar, work some years with/for a senior attorney at law, etc). But not all lawyers (juristes) are "avocats". Many of those lawyers (= juristes) choose to do something else than go to court to make a living. Many become legal advisor (conseiller juridique) on the payroll of a company or a public office. So they are employees, actually mostly managers or executives with a monthly pay. Too often do I hear translated TV-series and films call those lawyers (= legal advisors) "avocats". It's wrong. And when it comes to translating U.S. trials in French, it can get worse in regard with the translation of the various titles that people with a law degree wear in the U.S. judiciary system.
    Last edited: Jul 19, 2017
  10. Lex est quod notamus

    Lex est quod notamus Member

    English - USA
    I do agree with you, Phil.

    It's all a muddle really. In fact, in most places in the US it is illegal to refer to yourself a lawyer (except in casual conversation, but here I'm talking about misrepresentation) without being admitted to a state bar. Having a law degree is not enough. It makes you a law clerk (at best), and in a lot of places there are really strict rules about the type of work an "unlicensed" law-school graduate can do; essentially, they can only do paralegal work ("clerking"). If it's attorney work, they have to pass the bar. And being a juriste d'entreprise ("in-house counsel" or "corporate counsel") requires passing the bar as well because the term itself implies that you are a lawyer licensed to practice – whereas in France this is the opposite.

    As such, this is ripe territory for confusion when translators try their hand at finding an equivalent, because people working as in-house counsel in the US actually are licensed lawyers who have passed the bar, so translating them as avocat seems the right choice at first, but if they were really working in the French system, they wouldn't be avocats!

    (None of that applies to England and Wales, of course, where solicitors do not always have "rights of audience" to plead in court, but are still "lawyers".)

    It's also worth noting, for the record, that the term avocat shares the same root as the English advocate (n.), the first meaning of which is a person who "advocates" or pleads the cause of another before a court. Which makes sense: if you can't plead, you're not an avocat.
  11. Phil512

    Phil512 Senior Member

    Français - Belgique
    Great stuff, Lex, thank you ! You have a huge knowledge of various legal systems and you agree with my point of view for even more reasons than I thought. By the way, I learned some very interesting things about the U.S. legal system. I am amazed to read for the first time that you should pass the bar to be a legal corporate counsel. Totally amazing... but I should not be mesmerized at all since this theme comes up in both the novel and the movie called "the firm" (John Grisham with Tom Cruise) where it's explicit.
    Translation work has indeed become very difficult.
    Finally, as for the origin of the words "avocat" and the verb "to advocate", I knew. For the noun, well, I did not know that you, Anglo-Saxons, were using it. Well, to tell you the truth, I saw it in something that seems totally impossible to me, which is - if my memory serves me well - "the Judge Advocate General" in the U.S. military justice system. Another wonder :eek:. Thanks so much !

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