I have not taught such a course but Neil Foster and I have thought a bit about the matter. One factor I would stress is that in the commonwealth the common law of torts plays a significant role in regulating the relationship between the government and the citizen. The common law principles of tort work the same whether the defendant is the state or a private actor.
This is much less true in US law, where torts against the state (the federal state in particular) are governed either by "constitutional torts" or a variety of statutory schemes. (FTCA, "1983" claims, Bivins actions) They are for the most part, thought of as conceptually different categories than common law torts.
Neil and I also talked about differences in how the breach of statutory duty is conceptualized. And I recall he published a paper on that topic.
-Chaim Saiman
Villanova Law School
-