Comparison between US and UK Forms of Government

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18th May 2020 Politics Reference this

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Although our constitution makes it practically impossible that we could ever make the change, many over the past century have argued that the United States government would be more effective if it used a parliamentary system rather than a presidential one. This is the form of government used by most of the world’s democratic republics (Sargentich, Presidential), with the British system being the iconic example. However, I maintain that apologists for parliamentarianism miss key points in their arguments with respect to changing historical context and the evolving nature of both presidential and parliamentary systems, and that their arguments often make unwarranted assumptions about the relative desirability of various outcomes that may result from the adoption of one or another system. Further, I think the link between basic forms of government and specific political outcomes is often not as well established as parliamentarians would have us believe. In consideration of presidential systems and parliamentary systems, I will focus primarily on the US system as outlined in the US constitution, and on the British system, in its current form.

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As used in this paper, the major difference between a parliamentary and a presidential system (such as we have in the US) is that in a parliamentary system the head of government (often a prime minister), rather than being directly elected by the people, is appointed by the parliamentary party who is in power following a general election. He acts as a party representative and serves at the party’s will. This is often touted as an advantage, under the assumption that such a unification of the executive and legislative bodies is less susceptible to gridlock (wherein the government is (potentially) unable to pass laws or get anything substantive done, because the president and the legislature are at odds with one another). Another consequence of this arrangement is that it is easier to recall the head of government should his party lose faith in him. This is in contrast to the presidential system in place in the US, where the president can only be recalled under extreme circumstances, and even then it takes an extraordinary agreement by members of congress to do so (something which has become increasingly unlikely as government has become more polarized). It is also maintained that the unified parlimentary government lends to a greater assignment of responsibility, as there is less tendency to ‘pass the buck’ between the executive and the legislature. All of this is counted as advantageous to the parlimentary system (Manuel 1998).

But this view can be questioned on several points. Firstly, there is the question as to whether either form of government still functions in the way that the arguments for or against assume: the check on the executive offered by the possibility of a parliamentary vote of no confidence, for instance, is in fact rarely exercised in the modern British government (Norton 2016). And the office of US president, liable in the parliamentarian view to be hobbled into ineffectuality in the case of divided government (wherein one or both houses of Congress are of the opposing political party to the President’s) has in fact grown steadily in power from administration to administration, such that a prime concern today is not so much one that invisions an enfeebled president, unable to act, as one in which the president’s power is seen as unchecked, outside of the ability of Congress or the judiciary to rein it in (Ginsburg 2016). Further, there is the question as to whether unhindered majorities would, in practice, enact legislation that most American voters support. In a polarized, two-party system, most Americans might favor policies that lie significantly more to the center than those advocated by either political party. The fact that they lean one way or another doesn’t mean that they support the far-left or -right views of the separate parties: on the abortion issue, for instance, while the Republican party touts a desired policy of no abortions whatsoever, the Democratic party favors completely unrestricted access to abortion; it is probable that most Americans would prefer neither of those options (Fiorina 2014). And although there may be less blame-shifting in a parlimentary system, the unification of the head of government and the parliament makes for a less transparent and more secretive government in general (Strøm 2003).

Another contention is that the separation of the heads of government and state in parlimentary systems allows for the respect and honor due the state by patriotic citizens to be held aloof from the vicissitudes of political infighting and from disappointment or frustration over unpopular governmental policies. In the British system, for instance, the head of state is a hereditary monarch, whose role, being primarily ceremonial, is that of a ‘neutral’ party, to whom the allegiance due the state can be directed, irrespective of the particulars of governmental action. But in the US, where there is no historical ruling monarchy nor any ingrained deference accorded to title holders apart from their record of political action, it is not at all clear that anything like a ceremonial head of state would be afforded any sort of deference or viewed as a fitting receptacle for public reverence at all. Such is simply too much in opposition to deeply seated American values; most Americans can make no sense of the relationship between the average British citizen and his queen (Marcus 2018).

One of the most influential parlimentarians was the mid-nineteenth century political commentator Walter Bagehot. His writings about parliamentarianism influenced Woodrow Wilson, and remain foundational works in the field. But in many ways, the presidential and parliamentary systems about which he and Wilson wrote are long gone, having been so transformed as to make many of the points moot. Wilson, for example, wrote in defense of the parliamentary system during a period after the civil war which had been dominated by weak presidents: Johnson, Grant, Hayes, Garfield, and Arthur were relatively ineffective as presidents, and held office during a period in which Congress was dominant. But Wilson lived to see stronger presidents such as McKinley and Theodore Roosevelt in office, and this seems to have swayed him from his parliamentary infatuation by 1908 (Sargentich, Limits 692). Bagehot, similarly, was commenting on British parliamentary government during a period of relatively weak political parties, a period before the amplification of the power of the prime minister and of the civil service. There is evidence that he would have found such developments alarming (ibid., 694-5.)

Many parlimentary systems are proportional, meaning that, rather than the winning party getting all of the power, the various parties gain seats in parliament proportional to the number of votes they receive. This can be considered an advantage for several reasons: firstly, the government seems more representative of the people’s will, since minority voting blocs are represented in the government as minority sections of the legislature; secondly, this means that the majority party, in order to get things done, must work with the smaller parties, thus promoting cooperation among the various factions and avoiding the ‘win at any cost’ mentality that can come to dominate the US system; and finally, it allows minority parties to take hold and grow—in the US (and in most presidential systems) the two-party system is deeply entrenched, and it is nearly impossible for a third party to gain enough ground to be competitive.

But in fact, the parliamentary system often functions to suppress the minority view, since the majority has essentially unchecked power during its time as ruling government. And in cases where a coalition government must be formed, the larger party has little incentive to offer any but the most token of concessions to the smaller faction; the smaller group will be expected to vote with the larger party at every opportunity. In cases where no strong majority arises, the parliamentary system can wind up in a sort of deadlock of its own, wherein weak governments are formed and are dissolved in a futile cycle. Britain is right now in the middle of a months-long deadlock over Brexit (Cook 2019). And the possibility of coalition governments hasn’t created any serious rivals to the deeply entrenched (since the 1920s) Labour and Conservative parties (Crowe 1986).

Standard arguments also maintain that a parliamentary system makes for stronger, more disciplined parties, and a presidential system toward weaker, more fragmented parties. But this fails to explain the steadily growing influence of the two main parties in the US system, and the increased discipline among party members. Those affiliated with one or the other party vote consistently along party lines, which flies in the face of most predictions about presidential systems. It seems clear that what we have in the US is a unique system, and there really is no data from which we might make predictions about its future. No one knows how long a government like ours can remain stable, as there has never been a government like ours.

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Of prime concern in this debate are the goals and benchmarks themselves by which we measure the success or failure of a particular governmental system. Trying to judge disparate systems on, for instance, the ease with which they are able to pass legislation may be missing the point. In INS v. Chadha, the US Supreme Court commented, “Convenience and efficiency are not the primary objectives—nor the hallmarks—of democratic government” (462 US 944 (1983). And in Bowsher v. Synar, they said:

That this system of division and separation of powers produces conflicts, confusion, and discordance at times is inherent, but it was deliberately so structured to assure full, vigorous, and open debate on the great issues affecting the people and to provide avenues for the operation of checks on the exercise of governmental power (478 US 714, 722 (1986)).

This sort of recognition that particular ‘advantages’ of the parliamentary system might in fact be exactly what our system of government was designed to prevent is a key to this whole argument. The debate must be reframed. For instance, one study, comparing the rates of success of prime ministers vs. presidents, rated each by how many of their policies they were successfully able to enact (Cutler 1985). But this misses the point of our system of checks and balances. The president’s policies are not the sole metric for success in our government, as though there were no value to policies introduced from separate branches of government. And, of course, to a citizen whose goals do not align with that of the president or the majority party, any obstacle to passage of their agendae might be seen as a great virtue.

Finally, there is the question of how strong the purported link between these basic forms of government, and various political or social outcomes, really is. With regard to ‘divided government’ and deadlock, for instance, David Mayhew makes a lengthy argument in support of his claim that “important laws have materialized at a rate largely unrelated to conditions of party control” (Mayhew 1996).

Without claiming that the presidential system is perfect, I would simply like to point out that the arguments against it are not necessarily as cut-and-dried as some would have them.

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