Which Political System, the British, German, or American, Is Most Conducive to. Effective Political Leadership? By: Christina R.

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1 Durano 1 University of Westminster School of Social Sciences, Humanities and Languages 1POL411: Presidents, Prime Ministers and Parliaments: Political Leadership in the Western World Which Political System, the British, German, or American, Is Most Conducive to Effective Political Leadership? By: Christina R. Durano Student No.: w c.r.durano88@tcu.edu Phone No.: Module Leader: Dr. Raouf Tajvidi Seminar Leader: Dr. Samuel Azubuike Exam Substitution December 2008

2 Durano 2 Introduction The purpose of this essay is to explain which political system, the German, British, or American, is most conducive to effective political leadership. The primary hypothesis is that the British system is most conducive to effective political leadership because its executive has the most power of the executives in the three systems. In order to explore the effectiveness of the political leadership in the German, British, and American political systems, this study will examine the each country individually and the extent of each executive s power in the three nations. Political leadership is defined as a process by which governments try to exercise control over public policy decisions (Helms, 2005: 4). Various types of people can exert political leadership executive leaders, legislative leaders, interest group leaders, and other authorities. However, this essay will examine political leadership of executive office-holders in three countries: Germany, Great Britain, and America (Helms, 2005: 3). In the 19 th century, several people created theories of political leadership. Thomas Carlyle belonged to the Great Man School of political leadership and believed that great leaders were agents of social and political change with God-given qualities, and that they could change history (Elgie, 1995: 5). Herbert Spencer from the Cultural Determinist School argued the opposite, claiming that leaders were products of their times who simply reflected social forces around them. Those from the Cultural Determinist School believed that the leadership environment ultimately shaped the leader s actions. However, Fred Greenstein synthesised these two schools of thought to form the Interactionist Approach to political leadership. The Interactionist Approach, the theory of political leadership that this essay will use, focuses on the interaction between the leader and the leadership environment and assumes that leaders are constrained by their ability to act freely (Elgie, 1995: 5).

3 Durano 3 The first section of this essay, Leadership Is Made to Share, will examine political leadership of the German executive, the Chancellor. It will highlight both the powers of and the checks on the Chancellor and explore how these elements affect the executive s ability to impact the outcome of political decisions. In particular, this section will elaborate on how the Minister Principle and the Cabinet Principle, as well as coalition government and the vertical and horizontal division of power, limit the Chancellor s authority (Elgie, 1995: 84). Moreover, it will explain why the system has so many constraints on the executive. Essentially, Leadership Is Made to Share will argue that German federalism places an excessive number of limits on the Chancellor, thereby limiting the effectiveness of his or her political leadership. The second section, Just Give It To Me, will explore the extent of the British Prime Minister s power, particularly with regard to the powers and limits of the position. Specifically, Just Give It To Me will outline how the British unitary system, centralised government, and presidentialisation of the premiereship strengthen the role of the Prime Minister and how parliamentary sovereignty, collective responsibility, and the vote of no confidence place checks on the leader. This section will assert that although the British system does place some checks on the Prime Minister, the leadership environment in the United Kingdom allows the Prime Minister to wield a great deal of power and ultimately is the most conducive system to effective political leadership. The final section of this essay, Splitting It Up, will analyse the role of the U.S. President and the leader s ability to affect change and influence policy. It will concentrate on the separated powers and the system of checks and balances, examining how each branch places limits on the others. Particularly, it will summarise the main duties of and limits on the executive. In short, this section will maintain that the U.S. political environment allows the President to lead to an extent, but the checks on the executive limit the effectiveness of political leadership.

4 Durano 4 The conclusion will argue that although leaders in all three systems, German, British, and American, can exercise political leadership, the British system is most conducive to effective political leadership because it places fewer limitations on the executive. At the same time, it will note that while the British system allows for the most effective political leadership, it may not be the most effective political system as a whole because of the lack of checks on the executive. Leadership is Made to Share: Dispersed Leadership in Germany The head of government in Germany is the Chancellor, with the head of state being the Federal President, who wields no major power (Padgett et al., 2003: 18). The Chancellor Principle in the Basic Law, or German Constitution, outlines three powers of the Chancellor. One of the foremost powers of the Chancellor is to determine the guidelines of government policy, or provide guidance about government policy (Schmidt, 2003: 28). This is the most important way that the Chancellor exercises political leadership. Secondly, the Chancellor bears responsibility for government policy to the Bundestag (Elgie, 1995: 82). This means that he or she is responsible for the affairs of the federal government and takes the blame or praise for the Ministries decisions. The third power outlined in the Chancellor Principle is to conduct business of the government in accordance with the rules of procedure adopted by it. This includes the right to be kept informed of departmental activities and thereby be involved in the policy-making process (Elgie, 1995: 82). Additionally, the Chancellor can nominate government Ministers, determine the number and offices of Ministers, and supervise the work of the Press office and Federal Intelligence Service (Elgie, 1995: 82). All these powers allow the Chancellor to influence government policy; however, the limitations reduce the effectiveness of his or her political leadership.

5 Durano 5 One of the most significant limits on the Chancellor is the horizontal and vertical division of power. Germany has a complex web of checks and balances, a system that allows each branch of government to amend or veto acts of another branch, because of it s history as Hitler s Third Reich, during which the executive gained too much authority and became a dictator (Roberts, 2000: 35). It divides power vertically by operating a federal political system, meaning sub-central units of government have certain guaranteed powers that cannot be taken away by the central government, and officially limits the sovereignty of national leaders. Germany s sixteen Land, or regional governments, have a significant amount of control over regional affairs and hold the exclusive legislative rights over broadcasting, education, health, and law and order (Elgie, 1995: 100). In addition to this vertical division of power, Germany also has horizontal division of power. The German parliament is divided into two houses, the Bundestrat, or upper house consisting of the heads of the sixteen Land that has veto power, and the Bundestag, the lower house and law-making body that elects the Chancellor (Schmidt, 2003: 56-57). Furthermore, the Constitutional Court has the power of judicial review, or the power to declare any piece of legislation unconstitutional (Elgie, 1995: 98). This network of checks and balances, as well as the horizontal and vertical divisions of power, creates a system of dispersed leadership where responsibilities are diluted (Elgie, 1995: 79). Although this concept of dispersed leadership alone limits the potential for effective political leadership, the Basic Law, or German constitution, also places several other limits on the executive. The Minister Principle in Article 65 of the Basic Law asserts that Federal Ministers conduct and are responsible for the business of their own departments; the Chancellor cannot give Ministers specific orders or bypass Ministers and give mandates to departmental civil servants (Ridley, 1966: 457). This encourages autonomy and gives Ministers complete authority in their individual Ministries. Additionally, it forces the Chancellor to play a coordinating role between Ministers who each want to

6 Durano 6 promote their own policy interests. This mediating role detracts from the Chancellor s ability to direct public policy (Elgie, 1995: 85). Furthermore, the Cabinet Principle limits the Chancellor s power by mandating Cabinet approval before sending a bill to parliament. Although this is rarely more than a formal ratification, there is still potential for discussion, particularly since coalition governments have ruled since 1949 (Elgie, 1995: 85). Since any disagreement in the Cabinet would damage the Chancellor s image, the Cabinet Principle ensures that there is general consensus within the Cabinet before the formal vote (Elgie, 1995: 86). Another structural limit on the Chancellor is coalition government, or forming coalitions to win a majority of votes. For example, in the 2005 elections, the Christian Democratic Union and Christian Social Union held 35.2% of seats, the Social Democratic Party held 34.3%, the Greens held 8.1%, the Left held 8.7%, the Free Democratic Party had 9.8%, and other parties held 3.8% (Bundestag, 2008). Since none of the parties had an absolute majority, the CDU/CSU and SDU formed a grand coalition so they jointly could control the government. Coalition government highlights the Chancellor s role as a conciliator by forcing the leader to cater to both the desires of his or her party and the coalition. Public differences between the Chancellor and the coalition are damaging to the government; therefore, policies are often diluted and the Chancellor is forced to compromise in coalition government. A final limit on the German Chancellor is the constructive vote of no confidence, which provides a way for the Bundestag to remove the Chancellor (Curtis, 1978: 245). In order for this to happen, the Bundestag must have an absolute majority vote to remove the Chancellor and an absolute majority agreement on a replacement. However, this is extremely rare and has only happened once, in 1982 when when Helmut Kohl replaced Helmut Schmidt (Elgie, 1995: 84).

7 Durano 7 Although the German political structure does give the Chancellor significant powers, it severely limits the effectiveness of his or her political leadership by placing significant checks on his or her decisions, notably the horizontal and vertical division of power, the Minister Principle, the Cabinet Principle, coalition government, and the constructive vote of no confidence. Just Give It To Me: Prime Ministerial Leadership in the United Kingdom The United Kingdom has a political system that is on the opposite end of the spectrum from Germany. Rather than having excessive checks on the executive that limit his or her ability to lead effectively, the British political system gives its head of government, the Prime Minister, many powers, much flexibility, and fewer limits. One of the most important powers of the Prime Minister is to create, abolish, and control cabinet committees (Helms, 2005: 70). This authority, which provides a stark contrast to the German Minister Principle, allows the premiere to play an active role in the structuring of committees, the assignment of the chair, and the selection of members. Another Prime Ministerial power is to call and chair cabinet meetings, as well as set the cabinet s agenda and summarise discussion at meetings. These responsibilities allow the Prime Minister to set a purposeful direction for the cabinet and thereby it s decisions (Elgie, 1995: 40). Thirdly, the Prime Minister can set elections within a certain time period. For example, if the Prime Minister s party is doing well during a possible election period, the premiere may decide to set an election since his or her party is strong; however, if the party is facing scrutiny at the time, the Prime Minister can choose to delay the election by up to one year. In addition to these and other formal powers, the Prime Minister also has several structural supports that enhance his or her power. First and foremost, unitary government strengthens the Prime Minister s position. Rather than checking and balancing each other, as in Presidential systems, the executive and legislative branches in

8 Durano 8 unitary systems support each other (Hague and Harrop, 2007: 336). For example, in the United Kingdom, the parliamentary majority elects a leader to become the Prime Minister. The Prime Minister retains a seat in parliament and only remains the executive as long as his party maintains control of the House of Commons (Elgie, 1995: 14). This strengthens the Prime Minister s position by giving him or her legislative support. Not only does the same party control both the executive and the legislature, but it also encourages intra-party unity by using the whipping system, which encourages party discipline in voting by serving as a liaison between the executive and parliament (Helms, 2005: 162). Since MPs typically vote along their party line, the dominant party can pass legislation quickly and efficiently. Dominant parties rarely see their measures defeated or even amended in parliament, which leads to increased Prime Ministerial power (Dunleavy et al., 2006: 37). Furthermore, centralisation maximises the Prime Minister s power by increasing the power of the central government over the local governments (Helms, 2005: 177). For example, when Prime Minister Gordon Brown wanted to alleviate the credit crunch by providing a bank bailout, he was able to do so overnight. However, when U.S. President George W. Bush attempted to do the same, he met a myriad of roadblocks. In the British centralised system, the central government is responsible for high politics like foreign affairs, taxation, welfare structure, and defence, whereas the sub-central government controls low politics such as the delivery of local welfare. Recently, the distinction between high politics and low politics has become blurred, increasing the centralisation of leadership responsibilities even more (Elgie, 1995: 27). Additionally, presidentialisation, the concept that Prime Ministers are gaining more prominence in the cabinet and almost acting like Presidents, has increased the power of the executive exponentially. In the past few years, the cabinet has become more reactive than proactive,

9 Durano 9 approving and rejecting committee decisions rather than making them (Helms, 2005: 88). With the creation of the Cabinet Secretariat during David Lloyd George s premiereship, the previously informal cabinet decision-making process became more centralised to the benefit of the Prime Minister (Elgie, 1995: 35). Although the British political system has several aspects that support strong executive leadership, it also limits the Prime Minister s power in some aspects. One of the most important ways it checks the Prime Minister is though parliamentary sovereignty. Essentially, parliamentary sovereignty means that no person or institution can overthrow the decisions of parliament. The sovereignty of parliament prevents the Prime Minister from exercising too much power and becoming above the law (Helms, 2005: 175). Collective responsibility, the responsibility of the entire executive branch for decisions, further limits the individual power of the Prime Minister. Although the Prime Minister is the first among equals, cabinet ministers can have significant leverage if they have an independent political base (Dunleavy et al., 2006: 31). Additionally, all decisions must be unanimous within the executive, which means that the Prime Minister needs the support of his cabinet to govern effectively and prohibits him for assuming too much individual power (Hague and Harrop, 2007: 337). Another limit on the Prime Minister is the vote of no confidence. The vote of no confidence in the United Kingdom keeps the Prime Minister accountable by providing a way to remove him or her from office (Huber, 1996: 269). A member of parliament simply introduces a motion of no confidence and, if the motion is successful, the Prime Minister is removed from office and replaced by another member of the dominant party, as chosen by parliament (Curtis, 1978: 236). This system for removing the executive is much simpler and more likely to happen than in the United States of America and

10 Durano 10 Germany. Additionally, since the Prime Minister s authority lies within the legislature, it is his or her obligation to step down if he or she loses the support of the majority (Helms, 2005: 161). For example, Margaret Thatcher held a strong position within the Conservative party and had a huge influence in Cabinet and Parliament until However, when the economy took a downturn and the poll tax was implemented, her relationship with the party became damaged so she resigned (Elgie, 1995: 44). Both the vote of no confidence and the obligation to step down with loss of parliamentary support keep the Prime Minister accountable. In short, although the British system places some limits on the executive, it allows him or her to exercise a significant amount of power more than both the American and German systems do and is thereby the most conducive to effective political leadership in the executive realm. Splitting It Up: Divided Leadership in the United States The United States of America s political environment synthesises the British and German systems. While it has significant checks and balances like German federalism, it also gives the President, the U.S. head of state and head of government, a sufficient amount of individual power. The United States adopted a system with independent executive, legislature, and judicial branches in which each branch checks the others because of its history as a British colony, during which the colonist s rights were violated (Hargrove and Nelson, 1984: 13). The purpose of this system is to provide accountability and prevent each branch of government from exerting too much power. For example, the President appoints judges and departmental secretaries, but the Senate must approve these appointments. The Congress can pass a law, but the President can veto it. The Supreme Court can rule a law to be unconstitutional, but the Congress, with the states, can amend the Constitution (Constitution Online, 2008).

11 Durano 11 Article II of the U.S. Constitution outlines the President s powers. The primary duty of the executive is to make sure all laws are carried out (Hague and Harrop, 2007: 331). Additionally, the President can appoint judges, ambassadors, and other officials. This allows him to play a role in the operations of levels of government other than the executive (Hargrove and Nelson, 1984: 40). Furthermore, the U.S. President has the authority to place policy recommendations before Congress. Although he cannot rely on his party s supporting the recommendations like the British Prime Minister can, this authority still allows him to have a say in national policy (Hargrove and Nelson, 1984: 40). Another key power of the President is to deploy troops. As the Commander-in-Chief of the military, the President exercises significant power over national defence. However, he does not have supreme power over the military, evidenced by the fact that he cannot declare war (Hague and Harrop, 2007: 331). Moreover, the executive can make treaties with foreign nations. This gives him significant authority over foreign policy, a power that executives of other nations don t always have (Edwards and Wayne, 1985: 289). Regarding the legislative realm, the President can both call emergency sessions of Congress and force adjournment when the two houses of Congress cannot agree on adjournment, as well as veto acts of Congress (Hargrove and Nelson, 1984: 40). In addition, the President has the power to pardon offences (Constitution Online, 2008). Although the U.S. President has significant powers, he also has many limitations. One of the most important checks on the President is judicial review. Judicial review essentially means that the court can declare any legislative or executive act unconstitutional. This policy ensures that the President does not violate the constitution (Hague and Harrop, 2007: 330). Furthermore, the President can be removed by impeachment. Although it is not as easy to remove the U.S. President as it is to remove the UK Prime Minister, it is easier to remove the President than the German Prime Minister. Two Presidents have been impeached by the House of Representatives in America s history: Andrew Johnson for

12 Durano 12 removing the secretary of war without the Senate s approval in the 1860s and Bill Clinton for grand perjury and obstruction of justice in the 1990s. Neither President, however, received enough votes in the Senate to be removed from office (Constitution Online, 2008). The difficult but doable process of impeachment keeps the President accountable to the legislature and judiciary. Another check on the President is the veto override. If the President vetoes a piece of legislation, Congress can override the veto with a 2/3 majority in both houses, the Senate and the House of Representatives. In America s history, Presidents have vetoed 1,484 bills and 106 of them have been overridden (House of Representatives, 2008). The provision for veto override ensures that legislation the Congress feels strongly about will pass, regardless of the President s opinion. Additionally, Senatorial approval, required for departmental and ambassadorial appointments as well as for treaties, ensures that the President does not appoint officers solely based on nepotism and that he does not enter into risky treaties (Hague and Harrop, 2007: 332). U.S. Presidents also have a term limit of four years and two terms. At America s founding, the President did not have a limit to the number of terms a President could serve. However, after Franklin Delano Roosevelt served four terms as U.S. President, Congress enacted a term limit to prevent Presidents from ruling for too long and gaining too much power (Congress Online, 2008). Other limitations on the President include his inability to declare war, enact taxes, and allocate funds (Hague and Harrop, 2008: 332). Essentially, the U.S. political system is a synthesis of the German political system and the British political system. While it places significant checks and balances on the executive like Germany does, it also gives the executive the opportunity to wield a sufficient amount of independent political power, as in British system.

13 Durano 13 Conclusion In conclusion, political leadership is a process by which governments try to exercise control over public policy decisions (Helms, 2005: 4). The German, British, and American political frameworks differ significantly in the amount of power held by the executive. In the German political system, the Chancellor has the power to define policies, oversee Ministers, and conduct business in accordance with the rules of procedure adopted by the government. However, several limits prevent the Minister from becoming too strong, including the Minister Principle, the Cabinet Principle, the horizontal and vertical divisions of power, coalition government, and the constructive vote of no confidence (Elgie, 1995: 82). The British political framework sits on the opposite end of the spectrum from Germany. The Prime Minister has the right to call and chair cabinet meetings; decide the Cabinet s agenda; create, abolish and chair cabinet committees; and set elections. Furthermore, unitary government, centralised government, the lack of judicial review, intra-party unity, and presidentialisation on the premiereship enhance the Prime Minister s power. However, the British system still does impose some checks on the executive, including the vote of no confidence, collective responsibility, and parliamentary sovereignty (Helms, 2005: 70). America sits in the middle of the two procedures. While it provides an intricate system of checks and balances like Germany, it also allows the President to exercise a significant amount of power, including ensuring all laws are carried out, appointing officials, placing policy recommendations before Congress, deploying troops, vetoing legislation, making treaties, calling emergency sessions of Congress, forcing adjournment of Congress when the two houses cannot agree upon adjournment, and pardoning offences. Restrictions on the U.S. President include impeachment, term limits, judicial

14 Durano 14 review, Senatorial approval for appointments, Congressional approval for treaties, veto override, and the inability to declare war (Hague and Harrop, 2007: 331). Although each political system has its own strengths and weaknesses, the British system is most conducive to effective political leadership because it gives the executive the most power of the three systems and places the fewest limitations on the executive leader.

15 Durano 15 Bibliography Curtis, M., Comparative Government and Politics: An Introductory Essay in Political Science. New York: Harper and Row, Publishers, Inc. Dunleavy, P. et al., Developments in British Politics. Basingstoke: Palgrave Macmillan. Edwards, G. and Wayne, S, Presidential Leadership. New York: St. Martin s Press. Elgie, R., Political Leadership in Liberal Democracies. Basingstoke: Macmillan. German Parliament, German Bundestag. German Bundestag. Available from: [Accessed 8 December 2008]. Hague, R. and Harrop, M., Comparative Government and Politics: An Introduction. Basingstoke: Palgrave Macmillan. Hargrove, E. and Nelson, M., Presidents, Politics, and Policy. Baltimore: Johns Hopkins University Press, Helms, L., Presidents, Prime Ministers, and Chancellors: Executive Leadership in Western Democracies. Basingstoke: Palgrave Macmillan. House of Representatives, House of Representatives. House of Representatives. Available from [Accessed 25 November 2008]. Huber, J., The Vote of Confidence in Parliamentary Democracies. American Political Science Review. 90 (2), Padgett, S. et al., Developments in German Politics 3. Basingstoke: Palgrave Macmillan. Ridley, F. F Chancellor Government as a Political System and the German Constitution. Parliamentary Affairs. 19, Roberts, G., German Politics Today. Manchester: Manchester University Press. Schmidt, M., Political Institutions in the Federal Republic of Germany. Oxford: Oxford University Press. U.S. Constitution, U.S Constitution Online. U.S. Constitution Centre. Available from: [Accessed 25 November 2008].

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