Comparing the U.S. to other western countries is fraught with pitfalls. The English rule discourages private litigation, which is a more reasonable practice in Europe where there is aggressive public enforcement of the law. It's not a sane practice in a country where everything from labor rights to health and environmental rights are largely enforced through private litigation (by design).
I assure you that there is loads of private litigation in European countries (eg UK). There's even a term for it "compo culture", there are ads on TV looking for people who have been injured and they sue the other party.
We call those "ambulance chasers" in the US (though the act of actually following ambulances in search of potential clients is barratry and a crime). I had no idea you guys had them.
As the article mentions, but not by name, the US has a similar rule typically called "prevailing party fees". The article also mentions in the US the prevailing party fees must be triggered by statute or a provision of a contract - but fails to mention this is done quite frequently, in fact so much so that I would say while each party bearing its own fees is the rule in the US by default, but the exceptions (prevailing party fee triggered by statute or contract) are used more generally than the default.
Aside from common law vs civil law, Europe and the US have fundamentally different legal systems (adversarial vs non-adversarial). I think the non-adversarial system supports the English Rule, while the US adversarial system unnecessarily drives up attorneys fees and costs so legislators authorize attorneys fees only in specific types of cases where it is justified, and of course where a provision is included in a contact (of course parties in the US have the ability to contract such provisions).
