This Article describes a comparative research project studying judicial discretion in criminal sentencing in California and Germany.  Both jurisdictions have statutory provisions that permit trial court judges to exercise discretion in calculating the length of sentences in criminal cases.  However, to best understand how this discretion works in practice, researchers must look beyond legal secondary sources and refer to judicial decisions that illustrate these discretionary limits.  This is standard practice for a common law jurisdiction like California.  However, surprisingly, this method also applies to Germany, a civil law jurisdiction.  Furthermore, for the German portion of this research, a practice-oriented treatise proved to be a superior resource to statutory commentaries because it offered a comprehensive, illustrative list German case law citations that included sentencing examples.