The following set of tables was originally designed to enhance lectures I presented in an Introduction to American Politics course several years ago. It received high praise by the primary class professor, Dr. W. Robert Gump (and other faculty to whom he has subsequently presented it to). At his request I have made it available to others and have since expanded its scope and detail. This latest version was updated in the fall of 2000.*
SYSTEM-LEVEL CHARACTERISTICS
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United States
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Great Britain
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France
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Germany
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Type of System (see "Executive" below)
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Presidential
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Parliamentary
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Semi-presidential
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Parliamentary
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Current Constitution
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The Constitution of the United States, adopted in 1789
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Unwritten, it is a collection of statutes and practice that has evolved over several centuries
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The Constitution of the French Fifth Republic, adopted in 1958
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"Basic Law," adopted in 1949
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Territorial Centralization
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Federal; 50 states which have significant power
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Unitary, although some power is "devolved" to Scotland, Wales, and Northern Ireland
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Unitary, although in the 1980s, some power was granted to each of the 22 regions
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Federal; 16 states (Lander), which have a great deal of power
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PARTIES AND ELECTIONS
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United States
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Great Britain
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France
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Germany
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Electoral System
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For all national elections, plurality winners in single member districts (also known as a "winner-take-all" system)
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For elections to the House of Commons, plurality winners in single member districts
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For elections to the National Assembly and the presidency, a double ballot system (plurality winners in second round) in single member districts
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For elections to the Bundestag, plurality winners in single member districts for half of the members, and proportional representation (with a 5% threshold) for the other half
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Party System
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Two parties, but third parties and independent candidates sometimes have considerable though short-term influence
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Two parties, although the Liberals (under various names), the Scottish National Party, and the Plaid Cymru (the Welsh equivalent of the SNP) attract significant vote shares
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Multiple parties, but the double ballot electoral system encourages electoral alliances, so typically the second round of voting is between one of the two main parties of the left (Socialists and Communists) and the right (Rally for the Republic and Union of French Democrats); also, in the past two decades, the far right National Front has been able to make significant gains in local elections
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Multiple parties, but only two (the Socialists and the Christian Democrats) are strong enough to control government, while three others (Greens, Free Democrats, and the Party of Democratic Socialism) can be considered potential coalition partners
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LEGISLATURE
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United States
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Great Britain
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France
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Germany
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Name
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Congress
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Parliament
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Parliament
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Parliament
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Lower House of Legislature
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The House of Representatives; 435 members, elected for 2 year, fixed-length, terms
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The House of Commons; number of members varies, but as of 1997, 659 members, elected for a maximum of 5 year terms; elections may be held earlier if the Prime Minister so desires; this occurs in cases when it is politically advantageous to do so, or, when the majority party loses the "confidence" of the HOC, which typically means that they have been defeated in a vote on a non-trivial piece of legislation
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The National Assembly; 577 members, elected for a maximum of 5 year terms; it is the prerogative of the president to dissolve the NA and call for new elections
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The Bundestag; 656 members, elected for a maximum of 4 year terms; elections may be held earlier if the Chancellor so desires; this occurs when in cases when it is politically advantageous to do so, or, when the majority party loses the or, if the majority party loses the confidence of the Bundestag (this is procedurally more difficult than in Great Britain)
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Individual Members
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Significant role for individual members
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Little role for individual members
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Some role for individual members
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Some role for individual members
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Legislative Committees
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Many standing (or permanent) committees; they play a very important role in the legislative process
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Mostly ad-hoc (or temporary) committees; they play a fairly limited role in the legislative process
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Have a fairly significant role, working with government to amend proposed legislation
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Like American Congressional committees, they play an important role in reviewing, investigating, negotiating, and amending proposed legislation
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Upper House of Legislature
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The Senate; 100 members, each popularly elected by state for 6 year terms; plays in equal role in the legislative process
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The House of Lords; number of members varies, but as of 1997, about 1,200 appointed members (length of terms and criterion for appointment vary); plays only a minor role in the legislative process
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The Senate; 321 members, selected by electoral colleges from 3 different levels of local government for 9 year terms; plays only a minor role in the legislative process
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The Bundesrat; 69 members, appointed by state governments (as few as 3 and as many as 6 from each); plays an important but not quite equal role in the legislative process
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EXECUTIVE
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United States
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Great Britain
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France
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Germany
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Executive
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A president who is popularly elected to a 4 year term is both head of state and of government; his power and tenure are not linked to the legislature
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The monarch is a ceremonial head of state, while the prime minister is head of government and leader of the majority party in the HOC; power and tenure are directly linked to the legislature
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A "dual" executive, which includes a president who is popularly elected to a 7 year term and functions as head of state and exercises control of government with a prime minister, who is appointed by the president, is leader of the majority party in the NA and whose power and tenure are linked both to the president and legislature; the president's power and tenure are not linked to the legislature
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A president who is selected by a special assembly to a 5 year term is (mainly a) ceremonial head of state, while the chancellor (prime minister) is head of government and (typically) leader of the majority party; the chancellor's power and tenure are directly linked to the legislature
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Cabinet
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Cabinet members ("secretaries") are appointed by the president, subject to approval from the Senate; they play little role in government
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Cabinet ministers are appointed by the PM based mainly on their record of party service; they play the leading role in government
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The "Council of Ministers" is appointed by the president, typically reflecting his preferences and those of the PM (recall that the 2 executives may be from different parties); they play a significant role in government
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Ministers are appointed by the chancellor based mainly on their record of party service; they play the leading role in government
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Bureaucracy (Civil Service)
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Fairly fragmented, not well respected, and typically not recruited based on substantive knowledge or skills; they are largely independent
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Organized into 6 "departments" (as of 1997) which are centralized and fairly closely tied to their associated government ministers; members are, by and large, a skilled and respected group of technocrats
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A centralized, specialized, and highly respected group of technocrats; these individuals typically attend one of the "grand ecoles" (national institutions of higher learning and training for government service and business) and operate fairly independently
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A centralized, specialized, and respected group of technocrats who operate fairly independently
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OTHER
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United States
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Great Britain
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France
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Germany
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Policy-making Process
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Formally, individual members of Congress initiate policy; legislative committees are instrumental in the formation of policy; it is fairly easy in many cases to amend legislation (especially in the Senate)
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The cabinet initiates and formulates policy; parliamentary committees sometimes play a role in its formulation; it is fairly difficult to amend legislation that the cabinet has proposed
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With a dual executive it is hard to make any generalizations: Typically the president works closely with the PM on policy initiatives and these are initiated and formulated through the Council of Ministers by the PM; although parliament can propose legislation, the Council's bills are usually given priority
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The cabinet proposes the majority of policy initiatives (30 members of the Bundestag may also jointly propose a bill) to the legislature; committees play an important role in shaping the legislation; amendments are not easy, but not impossible
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Role of National Judiciary
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The Supreme Court has equal status with Congress and the president. It has the power of "judicial review," meaning that the Court can review and declare as unconstitutional the laws and actions of these (and other governmental) institutions, as well as arbitrate conflicts between the national and state governments
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Because there is no written constitution as such, and, since acts of Parliament are considered "supreme," there is nothing analogous to American-style judicial review of governmental institutions
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While there is no tradition of judicial review in France, there is a Constitutional Council which is charged with the responsibility of reviewing proposed legislation for constitutional conformity; this is mandatory in the case of some types of legislation, or may come at the request of either the president, the prime minister, or 60 members of the NA or Senate
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As in the United States, the Constitutional Court has the power of judicial review: The Court can review and declare as unconstitutional the laws and actions of government and arbitrate conflicts between the national and state governments
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System of Interest Representation
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The "pluralist" model, meaning that in theory interest groups are free to form; these groups, which (in the main) enjoy autonomy from government freely compete at multiple points for access to, and influence in, the policy process; groups are often loosely organized since membership is voluntary; finally, more than one group may represent a single interest
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Mainly pluralist, but there is some (now more limited) institutionalized relations between certain groups (mainly labor) and government; these groups are typically more hierarchically organized, and membership is often compulsory; this type of interest representation is referred to as "neo-corporatism"
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A mix; pluralist, but, relations between government, and business and economic interests often fit the neo-corporatist model
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A mix; pluralist, but, relations between government, and business and economic interests often fit the neo-corporatist model
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Media
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Overwhelmingly privately owned and largely free of governmental regulation and censorship, they enjoy a constitutionally privileged status
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For the most part privately owned, although there is some public ownership and government retains the right to control and regulate the media
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For the most part privately owned, although there is some public ownership and government retains the right to control and regulate the media
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Overwhelmingly privately owned and largely free of governmental regulation and censorship, they enjoy a constitutionally privileged status
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Hancock, M. Donald. 1998. Politics in Western Europe: An Introduction to the Politics of the United Kingdom, France, Germany, Italy, Sweden, and the European Union. Second Edition. Chatham, NJ: Chatham House.
Mark Kesselman, et al. 1997. European Politics in Transition. Third Edition. Boston: Houghton Mifflin.