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Parliamentarism

Ramesh Ponnuru and a correspondent ask why, despite America's status as "the world’s greatest inspiration to freedom-lovers and young democracy movements for over 200 years" is it that "new democracies overwhelmingly choose the parliamentary form of government." The correspondent then goes on to contrast parliamentarism with federalism, which is just wrong. Canada has a parliamentary government and a federalism system not unlike America's. It's just that the provincial governments, like the federal government, feature unicameral government and an executive responsible to the legislature rather than directly elected by the people. I believe the reason that parliamentarism rather than American-style presidentialism has proliferated is simply that research indicates that American-style systems are more likely to break down and go undemocratic. You can see some of this work in George Tsebelis' Veto Players.

It's worth noting that even though nobody says it publicly this seems to be the consistent view of the American government itself. We've had a lot of influence over the political structures of a lot of new countries -- from Germany and Japan in the late 1940s down to Iraq today. Near as I can tell we've never encouraged a country to adopt the American form of government. We did set up a presidential system in Afghanistan, but with a unicameral legislature. Beyond that, we almost invariably encourage countries to do something Germany-esque with a weak President in the head-of-state role and a strong Prime Minister as head of government.

And of course if you were starting again from the ground up, it's very unlikely that anyone would deliberately reproduce the American system. Among other things, current practice doesn't replicate initial intention to any great degree so the status quo doesn't really represent anybody's idea of how the government should be set up.

April 28, 2005 | Permalink

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Comments

It's also probably worth noting that our form of government didn't come about because a bunch of people sat around and thought, "How can we come up with the best possible system of democracy?" There were real concerns and vested interests that skewed the whole set-up, as with southerners wanting the Electoral College so that they could use their slave headcounts to boost their influence without having the slaves actually vote. Etc.

Posted by: Brad Plumer | Apr 28, 2005 4:02:18 PM

It seems we also conquered all your examples where we set up the governments, and thus probable intentionally emasculated the said conquerees for a valid reason. Two declared war on US. One was harboring terrorists and the other had previously surrendered and was broken the terms of their surrender.

Posted by: Chad | Apr 28, 2005 4:05:23 PM

It seems we also conquered all your examples and thus probable intentionally emasculated the said conquerees for a valid reason. Two declared war on us. One was harboring terrorists who had decared war on us. The other we had defeated previously and was breaking the terms of their surrender.

Posted by: Chad | Apr 28, 2005 4:05:43 PM

The Presidential-Congressional system has been tried a lot in Latin America and the Phillipines, rarely very successfully.

Posted by: Gareth | Apr 28, 2005 4:05:58 PM

It was mostly the whiskey and the sexy; less so the presidential-congressional system doing the inspiring.

Posted by: praktike | Apr 28, 2005 4:07:46 PM

Strong independent executive with a weak parliament is good for an imperial kind of state. More democracy - less chance of starting 'preventive' wars for the benefit of business interests; Swiss and Scandinavians don't fight.

Posted by: abb1 | Apr 28, 2005 4:12:54 PM

I'm going to have to nitpick with you about Canada. The Federal Parliament is bicameral, but the Senate has little real power. Many of the provinical legislatures were bicameral historically, but they all abolished their upper houses. (Of course, bicamerality is beside the point here: the prototypical Westminster system is bicameral, as are Germany and Australia).

Posted by: Gareth | Apr 28, 2005 4:12:57 PM

abb1, chad: Westminster systems have a stronger, not weaker, executive than does a "separation of powers" democracy like the US.

Posted by: Gareth | Apr 28, 2005 4:19:10 PM

I guess I'm showing my lack of knowledge of these other systems. I thought the Prime Minister was the equalivent of the President. George Bush = Tony Blair. But after reading Matt, it seems that have both.

"Beyond that, we almost invariably encourage countries to do something Germany-esque with a weak President in the head-of-state role and a strong Prime Minister as head of government."

Who is Germany's President? I'm assuming Schroeder is the Prime Minister.

Posted by: Chad | Apr 28, 2005 4:25:38 PM

Strong independent executive with a weak parliament is good for an imperial kind of state.

Well, that's certainly true, but I don't think that was the original reason. As Brad Plumer noted, there was a very elaborate dance going on at that convention. It seems unlikely that they were pushing for a strong imperial executive, since one of the potential roadblocks was anti-Federalist sentiment. I still naively think that distrust of authority played enough of a role for them to create an adversarial three-sided government. The problems we've seen recently have not been due to a strong independent executive with a weak legislature; they have been due to a strong independent executive with a compliant legislature. Congress doesn't lack power, but the majority party in Congress, out of naked partisanship, refuses to use that power to check the executive even when the executive is disregarding the law. Thank goodness we have an independent judiciary. Oh, wait...

And Gareth, your point about strong executives is somewhat true; however, the strength of the parliamentary executive flows entirely from the strength of the legislative majority. The US President currently contains considerable freedom of action irrespective of the legislative fortunes of his party. (E.g., President Clinton didn't have to step down after 1994.)

Of course, Her Majesty Queen Elizabeth II is technically the head of state of the UK and Canada, but I'm guessing that you're not asserting that the Governor-General of Canada is a stronger executive than our President.

Posted by: mds | Apr 28, 2005 4:31:53 PM

Who is Germany's President? I'm assuming Schroeder is the Prime Minister.

Someone named Horst Koehler.

(No, I've never heard of him, either.)

And the German equivalent of the PM is called a Chancellor.

Posted by: sexualchocolate | Apr 28, 2005 4:34:48 PM

Mr. Yglesias, Mr. Gareth,

Some nitpicks -

The Philippines is an exception. It has had a presidential system with a bicameral legislature (Senate and Congress) from 1935. This was not imposed by the US, it was selected by the Philippine constitutional convention.

The dictator Marcos (who gained power by abusing a provision in the Philippine constitution of 1935 that does not exist in the US) imposed a parliamentary system with himself as head of state because he could manipulate such a system more easily.

The Philippines changed back to the constitution of 1935 post-Marcos (without the emergency power provision).

I am not convinced that a parliamentary system is less prone to abuse, and I also think that the reason parliamentary systems are common is historical, because most countries adopted them long before the US was a world power. There are very few cases of tabula rasa governments built post-1945. They were copying the true powers of the day, Britain, France, and Germany, or were ex-colonies of these powers.

Posted by: luisalegria | Apr 28, 2005 4:50:42 PM

I fully agree and it is great to hear an American saying it. France and the US have been consistently amongst the worst governed major countries. But you didn't mention what I see as the major reason. Power and responsibility don't go clearly together. And so Congress and the Administration can point at each other and say - "it's their fault".

Another feature of a Presidential government is that the President is commander in chief. Give somebody a title and they will want to use it!

Posted by: Jim Brady | Apr 28, 2005 4:54:06 PM

Ramesh is on to something. US schools extoll the importance of separation of powers and checks and balanced. The two ideas are almost mythologized.

But when it comes to designing foreign gvts, Americans don't implement a system with clear separation of powers or checks and balances. Why?

One sensible answer is conservatism. Iraq, Japan, Afghanistan and Germany all had pariamentary systems before conquest. The conqueror's inner Burkean kept the old system.

(This would explain why, unlike, Germany etc, the Phillipines and Cuba got a presidential-three-branches system. The Spanish hadn't set anything up, so it was Tabula Rasa.)

Another possibility is that the Americans know that Presidential systems with three branches just suck. In Latin American and Africa they usually lead to governmantal paralysis, dictatorships, and sometimes civil war.

Next Question: Would the USA be better off with a parliamentary system of gvt and a figurehead president/head of state?

Posted by: Ikram | Apr 28, 2005 5:00:48 PM

"It's worth noting that even though nobody says it publicly this seems to be the consistent view of the American government itself."

Consider that the interests of those who govern, and those who are governed, are distinct. Our form of government could easily be better for the latter group, and still not be favored by the former.

Posted by: Brett Bellmore | Apr 28, 2005 5:04:15 PM

The parliamentary system developed initially in countries with a reigning monarch, who was in fact the executive. In British history there was an ungoing erosion of monarchial power from the Civil War of the 1640s down through the 19th century when the monarch became basically a figurehead. A similar process occurred in the Low Countries and Scandinavia, so that the Legislature ended up taking on executive functions as well, through the office of prime minister or its equivalent. In other countries the monarchs were deposed (in some cases, murdered) when they refused to assent to the erosion of their power (see: France, Germany, Italy, Greece, Portugal, Russia, etc.) leaving the legislature supreme in that manner. France of course is something of an exception as France does have a strong executive independent of the legislature. I believe that many former French colonies have tried a presidential system, often with disastrous results (e.g., the "Emperor" Boukasa of the Central African Rep.) British colonies on the other hand have usually opted for a version of the British Parliamentary system.

Posted by: JonF | Apr 28, 2005 5:05:14 PM

I believe the reason that parliamentarism rather than American-style presidentialism has proliferated is simply that research indicates that American-style systems are more likely to break down and go undemocratic.

You may wish to invest in hood locks, and a mirror to check for devices under your car.

Also you may be surprised how much a hair or small slip of paper can tell you. See "Tinker, Tailor, Soldier, Spy" for more information.

Posted by: jerry | Apr 28, 2005 5:16:53 PM

Chad,
Most democracies have two executives- the head of government and the head of state. The head of state is usually a largely ceremonial role, while true executive power rests with the head of government.

In Britain, Queen Elizabeth is the head of state and Tony Blair is the head of government. In other countries that have adopted parliamentary systems but don't have monarchies (such as Germany or Ireland), they elect a President for the ceremonial head of state role a monarch would serve.

In the US, President Bush is both the head of state and head of government.

There are also semi-presidential systems where a parliamentary system is used for the legislature but the President also has executive power and is not just a figurehead- like President Chirac in France. In France, it has become tradition for the President to oversee foreign affairs and the Prime Minister to supervise domestic affairs. Of course, there is overlap and when the two are from the same party the President tends to take precedence.
---------------------------
Chad said: "I thought the Prime Minister was the equalivent of the President. George Bush = Tony Blair. But after reading Matt, it seems that have both."

Posted by: Ricky Barnhart | Apr 28, 2005 5:22:07 PM

New democracies have largely been set up under US, UK or European Community influence. Uk colonies followed UK practice at the time (US Constitution similar to imagined relations between Parliament and Crown in 18th Century, Australian constitution reflecting strong Bicameralism in view of still influential House of Lords etc).

More interesting with EC or US influence of new democracies since 1989 etc, the EC and US want to maintain their influence *after* the new democracies are established and therefore have interest in the concentration of power in executive with which they can deal confidentially and trading a lot of issues off against each other. Separation of powers and dispersal of powers more generally makes international cooperation much more difficult. Why would the US want a conquered country to have something like the US Congress which would make ratification and fulfilment of agreements with the US much more difficult? Similarly, a single arena for negotiation and high barriers to entry for non-establishment parties is useful for both EU member states and new democracies which they hope to make new member states. See the EU establishment fear of referenda as "Populism" as exhibit A.

Posted by: Otto | Apr 28, 2005 5:30:52 PM

It seems like the people in this discussion can't even agree who has the most "powerful" executive (ie, one that could be easily manipulated by the evil US after it conquers them), a Parliament where the head can get anything done, or an Executive where the head has no responsiblity to the legislature. The ambivalence makes me doubt the idea that we (or anyone) designs either form of government like that for malleability.

Posted by: Tony Vila | Apr 28, 2005 5:42:25 PM

mds hints at this, but one widespread initial conception of the US government was that the legislature would be the dog, the executive the tail. Only since the Civil War and especially in the 20th century has the presidency routinely rivaled or bested the legislature in terms of power. As Matthew noted, "current practice doesn't replicate initial intention to any great degree."

My view of the federal system has always been that it was dictated by the pre-Revolution structure. The states saw themselves as essentially independent; they were happy to impose limits such as the Bill of Rights on the federal government in large part to make sure it didn't meddle in their affairs. Remember also that initially the states elected the federal senators; direct popular election was only for the House. The constitution also, as Brad indicates, acknowledged the southern states' slave-related concerns.

In all, the Constitution's structure and allocation of power is kind of a kludge, but an elegant one -- if that's not too oxymoronic.

Posted by: Shelby | Apr 28, 2005 6:13:28 PM

wasnt there a West Wing episode about this ? Some African country was implementing a new democratic constitution. I seem to recall Toby and a law professor they had brought in to help having an argument about this in which they argue the merits of either system?

Something about based on experience the Ameican style of government has almost always led to a break-down of democracy because one person has so much power.

Posted by: Mihir | Apr 28, 2005 6:13:48 PM

Robert Dahl has a concise summary of the relative virtues of American Constitutionalism in his book HOW DEMOCRATIC IS THE AMERICAN CONSTITUTION? Short summary: not as much as it could be; that's why no one has followed us in Constitutional design. For a more detailed examination of the comparative virtues of Presidential and Parliamentarian systems, see Mark Tushnet and Vicki Jackson's COMPARATIVE CONSITUTIONAL LAW.

Posted by: Doug | Apr 28, 2005 6:37:50 PM

I like a lot of the suggestions so far. Here are my guesses, some of which reiterate things that have already been said:

1. The countries that have "learned" democracy from Western colonial or imperialist powers have tended to adopt, or be guided or compelled into, the form of democratic government popular in those Western countries that most influenced them.

2. Strong presidencies have suffered some discredit from the South American and African experiences, in which the Presidents often presided over despotic government, and "president" came to seem synonymous with "chief".

3. In monarchical societies in which there was already a tradition of a people's representative body, but one that was absolutely subservient to the monarch, it is natural for the evolution to democracy to take the form of a movement in favor of the supremacy of the people's representatives - that is, for the people's representatives to take over the executive functions of government. The English Revolution seems to be a more common model for the emergence of democracy rather than the fairly unique circumstances of Colonial America, the American Revolution and its aftermath. "New Worlds" don't come along very often.

4. The American system was devised by people who disparaged political parties or "factions", and sought to limit their influence. Since that time, I believe the existence of politicalfactions has come to be seen as a natural and inevitable democratic phenomenon, particularly in modern societies that are almost always undergoing some sort of dynamic social change. Parliamentary sytems seem more obviously designed to foster and accommodate parties that reflect emerging and contending political "natural kinds".

5. The most importantly unique aspect of the formation of the American system of government is that the Constitution was not written so much by groups of contending peoples in a state of anarchic turmoil and national crisis, as in Iraq, but by representatives of states, each of which already had a more or less stable, functioning government, but which sought to form a "more perfect union" out of those states. The major issues were not much over how to coordinate the efforts of various parties, sects or social groups, but how to coordinate the relations among the separate states - regulating interstate commerce, common currency, common system of defense, levying taxes for common purposes, etc.

Both systems have shown tendencies toward ineffectiveness, but for different reasons. In the American system, major legislation is inherently difficult, and the political system tends toward a debilitating conservatism and inability to reform and repond to social change and pressing needs - only lurching forward in response to major crises. Emerging political groups have difficulty in building coalitions and achieving legislative power, because they are held captive by the major "parties". In fact, what we call "parties" in the United States do not seem to be genuine parties at all, but service-providers that deliver election victories for their members by organizing coalitions and directing the flow of funds. Most of the coalition-building in America seems to take place at the sub-legislative party level, rather than as part of legislative activity itself. And the coalitions that are built often seem frustratingly incoherent and unresponsive to their own members.

Some parliamentary systems, on the other hand, have broken down into unworkable partisan fragmentation and instability, leading sometimes to permanent states of crisis or even the collapse of government. The price of stability in the American system is gridlock. The price of flexibility in parliamentary systems is the potential for chaos.

Posted by: Dan Kervick | Apr 28, 2005 6:49:22 PM

"HOW DEMOCRATIC IS THE AMERICAN CONSTITUTION? Short summary: not as much as it could be; that's why no one has followed us in Constitutional design."

You're right, our government isn't as democratic as it could be, which is in fact why it's worked out so well; We've been threading that narrow passage between the tyranny of the majority, and the tyranny of the minority.

The problem is that people look at us, and attribute that success to democracy, when it's actually due to limits on democracy.

Posted by: Brett Bellmore | Apr 28, 2005 7:25:22 PM

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