15479. Comparative Justice: Alternative Approaches to Incarceration Regarding Substance Abusers in the u.s., British & Dutch Systems. This research paper provides an overview and analysis of the domestic drug policies of three liberal Western democracies: United States, Great Britain (the focus will be on England as the policies vary somewhat in other regions of the UK), and the Netherlands. The paper focuses on the three criminal justice systems' treatment of the substance user/abuser, with a particular focus on alternative approaches to incarceration in the U.S., English and Dutch criminal justice systems. KEYWORDS: comparative criminal justice systems drug crimes US UK Netherlands substance abusers treatment punishment term paper. APA Style. 29 pages, 71 footnotes, 33 bibliographic references.