Confianza legítima y seguridad jurídica: la perspectiva comparada

Legitimate trust is a principle that has been incorporated, vertically or horizontally, in different legal systems, often with different legal bases, starting from private law to reach public law. However, it was multilevel constitutionalism that contributed to placing such figure at the center of doctrinal and jurisprudential constructions. Especially, in administrative law systems, its evolution in public law occurs essentially through the activity of judges, without ruling out that, in some European systems, constitutional and legislative data of the administrative procedure have supported the jurisprudential work. This work proposes a comparative law perspective to analyze and understand the principle of legitimate trust and legal security in the constitutionalism of England, the United States, France, Belgium, Spain and Portugal.