The subject of this study is the analysis of models of state sovereignty in modern legal systems that have developed within the Anglo-Saxon and Ibero-American legal traditions. The article examines the features of the formation and functioning of various concepts of sovereignty, including parliamentary sovereignty, constitutional sovereignty, and the socio-constitutional model of sovereign power. Special attention is given to the institutional mechanisms for the implementation of sovereignty, the role of constitutional norms, judicial practice, and international law in the development of modern state-legal systems. The work analyzes the peculiarities of the interaction between national and international law, as well as the influence of globalization and the internationalization of legal regulation on the transformation of the classical concept of sovereignty. The comparative analysis reveals both common trends in the development of modern constitutionalism and specific features of the legal systems of Anglo-Saxon countries and Latin American countries shaped by the influence of the continental legal tradition. The methodological foundation of the research consists of comparative legal, formal legal, and historical legal methods. Comparative legal analysis is used to compare models of sovereignty in Anglo-Saxon and Ibero-American legal systems, as well as to identify institutional and normative differences between them. The scientific novelty of the study lies in the formation of an author's typology of conflicts of state sovereignty arising from the interaction of various legal traditions and institutional models of public authority. The study highlights four main types of conflicts: institutional, normative, interpretative, and democratic. It is shown that the differences between Anglo-Saxon and Ibero-American legal systems are determined not only by the peculiarities of constitutional regulation but also by differences in understanding the sources of legitimacy of state power, the role of judicial practice, and the relationship between national and international law. It has been established that the Anglo-Saxon legal tradition is characterized predominantly by an institutional model of sovereignty implementation based on the principles of parliamentary or constitutional supremacy and the development of case law, while Ibero-American countries are forming a socio-constitutional model of sovereignty, which involves an active role for constitutional courts, expanded mechanisms for the protection of human rights, and a broader use of direct democracy institutions. The conclusion is drawn that in the context of globalization, state sovereignty is transformed and implemented within a multi-level system of interaction between national and international legal mechanisms.
Dmitrii Borisovich Tolstik (Thu,) studied this question.