Different traditions, legal systems, and forms of government.
It might be an interesting study to trace the development of legal systems and forms of government for Great Britain, France, and the United States up to 1815. France had an absolute monarchy until 1789; Great Britain began whittling that away in 1215 with the Magna Carta. The United States followed British examples and traditions because they had been colonized and the basic institutions, including representative government, were brought over from Great Britain.
France had to play catchup quite a bit beginning in 1789 and did not have a uniform code of laws until the Code Civile.
Something to think about before blanket condemnation. And no one had a democracy in 1815. France reverted to the Bourbon monarchy; Great Britain had a constitutional monarchy, and the United States was a constitutional republic.