德国和美国都建立了较为完备的违宪审查机制,但两国的违宪审查在审查模式、违宪审查的程序以及宪法法院裁判的效力等几方面都具有各自的特点,也表现出很多相通的共性。这正是两大法系相互学习和融合的结果.我们应充分学习和借鉴两国在这方面的优点,以便更好地发展我们的宪法监督体制。 Both Germany and the United States have established comparatively complete constitutional review mechanisms. However, the unconstitutional review of the two countries has its own characteristics in terms of the mode of examination, the procedure of constitutional review and the effectiveness of the constitutional court adjudication. It also shows many similarities in common. This is exactly the result of mutual learning and integration between the two legal systems, and we should fully study and learn from the advantages of the two countries in this regard in order to better develop our constitutional supervision system.