Comparative politics

• US vs. UK Constitution: nature & sources

  • Both shaped by the cultures of their respective nations e.g. US has stricter checks & balances because of the history of British monarchical rule, UK has more centralised govt due to evolution from powerful monarchy
  • US is codified, UK is uncodified
  • US is a single document supplemented by amendments & SC rulings, UK is drawn from statue law, convention, authoritative works, common law
• US vs. UK Constitution: provisions & principles

  • Both: provide for 3 branches of govt, set out representative democracies, provide for a bicameral legislature, provide for a SC, provide for fixed-term elections, provide for sub-national govts
  • US has separation of powers, UK has fusion of powers
• US vs. UK Constitution: the legislature

  • Both: provide for bicameral legislatures, have elected legislative chambers
  • Senate/House have the same legislative powers (& some individual powers), Commons much more powerful than the Lords
  • UK only has one elected legislative chamber
  • UK executive dominates the legislative programme, US president can propose legislation but is less able to ensure it's acted upon
• US vs. UK Constitution: the executive

  • Both heads of govt, initiate legislation, command army (can order military action without consulting the legislature), appoint to cabinet/govt positions
  • Both cabinets have members responsible for specific policy areas
  • US has more extensive checks & balances between executive/legislature
  • US executive can't serve in the legislature, UK executive drawn from the legislature
  • President can't call premature elections
  • UK has a greater concentration of power in the executive
  • US Cabinet has less authority: meets only at president's request
• US vs. UK Constitution: the judiciary

  • Both: use judicial review to consider govt actions, interpret the Constitution (technically), judges have security of salary/tenure
  • US can strike down Acts of Congress/executive actions as unconstitutional, UK can only issue 'declarations of incompatibility'
  • Parliament can easily pass a new law to resolve incompatibilities, Congress can't easily pass a constitutional amendment
  • US SC's existence is entrenched, UK SC could more easily be abolished with an Act of Parliament (& was only established in 2005)
• US vs. UK Constitution: federalism/devolution

  • Federalism/devolution have the same purpose of giving power to communities/regions
  • States & devolved assemblies have previously been challenged by the national govt e.g. Scotland's attempts to call 2nd referendum, SC rulings declaring state laws unconstitutional
  • States have power & sovereignty, devolved govt doesn't have sovereignty
  • States can legislate on things federal govt can't, Parliament shouldn't legislate on devolved policy areas
  • Federalism includes the whole country, no devolved assembly for England
• Congress vs. Parliament: structure

  • Both: bicameral, different parties can control each chamber (not really HoL), elected using FPTP, carry out work in committees
  • Neither House of Congress is 'superior' in the legislative process
  • Members of Congress can't also be members of the executive but UK executive is drawn from Parliament
  • Members of the House face election more frequently than the Commons
  • Bills are considered by the 2 chambers concurrently in the US, consecutively in the UK
• Congress vs. Parliament: lower chamber

  • Both: directly elected, delegate model of representation (need to be seen to be advocating for their constituents), whole chamber is elected at once
  • US representatives represent more constituents & larger areas than in the UK
• Congress vs. Parliament: upper chamber

  • Both focus more on legislation than the lower House: Senate has longer terms so less focused on constituents, Lords don't have constituents to consider
  • Senate is directly elected, Lords isn't
  • Senate seen as more prestigious, Lords known for its expertise
• Congress vs. Parliament: legislation function

  • Both have significant legislative power e.g. Parliament blocking Brexit, Congress withholding funds for border wall (2019)
  • Congressional members can introduce multiple pieces of legislation in a single session (not possible in the Commons)
  • President suffers regular legislative defeats, Commons govt majority
  • Congressional committees are far more effective than parliamentary legislative committees (govt dominated)
  • Party discipline limited in the US (fewer carrots/sticks for whips)
  • President can veto legislation, Royal Assent is a formality
• Congress vs. Parliament: representation function

  • Commons, Senate, House all represent constituents
  • Parliament more representative in terms of gender than Congress
  • Congressional district boundaries are drawn by the state legislature (allows for gerrymandering), constituency boundaries are drawn by an independent commission
• Congress vs. Parliament: oversight function

  • Both can remove the PM/president (vote of no confidence/impeachment)
  • Senate has oversight of all judicial & most executive appointments
  • Senate must ratify treaties, Parliament can't do this
  • Congress has greater control over the budget, UK govt's budget rarely defeated (govt resigns if it is)
  • Congress has the power to declare war, this is a prerogative power in the UK (but convention to consult the Commons)
  • Congress doesn't have an equivalent to PMQs
• President vs. PM: roles & powers

  • Both: head of govt, chief executive, choose a deputy (& the extent of deputy's powers), commander-in-chief
  • PM doesn't appoint judges, is party leader, indirectly chosen as PM, can declare war & deploy troops (royal prerogative), no term limits
  • President has greater scope to act unilaterally e.g. executive orders, also head of state, de facto party leader, can veto legislation, directly elected, can't declare war, 2 term limit, EXOP is larger than No. 10/Cabinet Office
• President vs. PM: accountability to US & UK legislatures:

  • State of the Union & King's Speech
  • Both can be removed: impeachment, vote of no confidence
  • US budget subject to intense bargaining/gridlock UK almost always passes
  • PM must regularly face Parliament (PMQs), President only has to for State of the Union
  • Confidence vote applies to the whole govt, impeachment only concerns the president
• President vs. PM: cabinets

  • Both: power of appointment (choose who is in the cabinet), cabinet members are responsible for a certain policy area
  • Senate must confirm federal appointments
  • US Cabinet members can't be sitting members of Congress, tend to be chosen for their expertise, no power vested in the Cabinet, members aren't necessarily party affiliated, president decides frequency of meetings
  • UK Cabinet drawn from the legislature, generally chosen based on loyalty/ideology/faction, PM is 'first among equals', collective ministerial responsibility, PM obligated to maintain regularity
• President vs. PM: presidential & prime ministerial govt

  • Both systems are criticised for an unacceptable increase in executive power
  • PM is part of the legislature & the executive, generally stronger than presidents
  • President is only part of the executive
• US vs. UK Supreme Court: similarities

  • Both have the power of judicial review
  • Judges have security of salary & tenure
  • Both are the highest court in their respective nations
  • Both can only review cases submitted to them
  • Justices can be removed by the legislature
  • Justices must recuse themselves from cases where there is a conflict of interest
  • Both rule on human rights cases
  • Interest groups can bring cases to the court & intervene in rights cases
• US vs. UK Supreme Court: differences

  • US: justices nominated by the president & confirmed by Congress, 9 justices, life tenure, can strike down laws as unconstitutional, rules on rights cases based on the Bill of Rights, more common for interest groups to submit amicus briefs
  • UK: justices appointed by an independent appointments, commission (chaired by the Lord Chancellor), 12 justices, must retire at 70/75, can only issue 'declarations of incompatibility', rules on rights cases based on the ECHR, more recent phenomenon for interest groups to intervene in cases
• US vs. UK electoral systems: similarities

  • Fixed-term elections
  • House & Commons are both all elected at the same time
  • Congressional & general elections use FPTP
  • Both 2 party systems (US is stronger)
  • Voting age for all elections is 18
  • People must register to vote
  • Restrictions on campaign finance
• US vs. UK electoral systems: differences

  • PM can use prerogative power to dissolve Parliament
  • Senate is elected, Lords isn't
  • Staggered Senate terms, whole Commons elected at once
  • Elections to devolved bodies use PR
  • 2-term presidential limit, no limit for PMs
  • President is de facto party leader, PM has to be party leader
  • UK party leaders nominated by MPs (sometimes members), presidential candidates chosen through primaries/caucuses
  • Constituency boundaries drawn by an independent commission, congressional districts drawn by state legislature
  • UK has much stricter campaign financing laws
• US vs. UK pressure groups: similarities

  • Business groups have stronger financial links to the Conservatives/Republicans
  • Insider groups with strong govt links are most successful (iron triangles in the US)
• US vs. UK pressure groups: differences

  • Unions have closer links to Labour (most MPs have a formal link) than the Democrats
  • UK pressure groups will have less success lobbying specific reps because elections are decided by national party popularity
  • Less tradition of lobbying the SC because it's less powerful
  • US has more access points
  • US pressure groups can more freely donate to/spend money on candidates
• US vs. UK political parties: campaign finance & party funding

  • Both rely on donations/fundraising
  • UK party membership is subscription based, no formal concept of membership in the US
  • Money is more influential in US politics
  • Spending in the UK is very tightly controlled: spending limits per constituency, per candidate
  • UK political ads are strictly controlled: free airtime for each party for a set number of Party Election Broadcasts (can't pay for any more)
• US vs. UK political parties: party systems

  • Both systems have safe seats/marginals, FPTP creates a two party system
  • Devolved bodies have more multi-party systems because of PR
• US vs. UK political parties: factions

  • Umbrella parties so unity is a challenge
  • Socialist faction in Labour & the Democrats
  • Factions more likely to break off to form a new party in the UK e.g. Reform
• US vs. UK political parties: policies

  • UK parties concur on a lot of issues: Labour often moves to the centre to capture disillusioned voters
  • Republicans/Democrats more ideologically distinct
  • US politicians have individuals brands (because more scope to diverge from the party platform)
• US vs. UK political parties: third parties & minor parties

  • FPTP makes it harder for 3rd parties to win
  • UK has some viable 3rd parties e.g. Lib Dems, SNP, Greens
  • US 3rd parties don't hold any major political office
  • US independents often have significant success in local/state elections
  • US 3rd parties struggle more because of the huge cost of candidacy