England’s common law emerged gradually over a longer period of development of a modern market; English judges were former barristers who, because they had defended clients in contractual disputes, had a personal appreciation for the market economy. Like Hadfield and Rubin,and Andonova see a growing convergence between civil and common law systems in the 20th century. They are critical of this evolution (which they term an anti-market bias) because they view it as a restriction on market-oriented arrangements.