CONTRASTS BETWEEN

THE AMERICAN AND BRITISH

POLITICAL SYSTEMS

Contents

 Introduction
 The Constitution
 The Executive
 The Legislature
 The Judiciary
 Political Parties
 Elections And Campaigns
 Style Of Politics

INTRODUCTION

Elsewhere on this web site, I have outlined in some detail explanations

of both the American political system [click here] and the British political
system [click here]. As someone who is intensely interested in politics
generally, and British and American politics most especially, I am
fascinated by the many differences between the political scenes on the
two sides of the Atlantic. Inevitably, I am oversimplifying somewhat,
but the following differences strike me as instructive.

THE CONSTITUTION

 Perhaps the most fundamental difference between the American

and British political systems is the constitution - or the lack of
 one. The United States has a written constitution as does the vast
majority of nation states. The UK does not have a single
document called the constitution but instead its constitutional
provisions are scattered over various Acts of Parliament.
 The American constitution is hard to change and, in current
political circumstances, perhaps impossible to change in any
meaningful respect. The Equal Rights Amendment - which sought
to provide equal rights for women - failed and there has been no
succesful amendment of the US Constitution - except for one
technical measure - since 1971. What for practical purposes
constitutes the British Constitution - various Acts of Parliament -
can be changed by a simple majority in the legislature. For
instance, the current Coalition Government introduced fixed terms
for the House fo Commons by passing the necessary legislation.
 In the United States, political discourse frequently makes
reference to the constitution - typically Republicans arguing that
Democratic initiatives are 'unconstitutional'. Besides the fact that
the UK does not have a constitution as such, it is rare for British
politicians to argue that the actions or proposals of their
opponents are illegal or ultra vires.
 In the United States, because of the strict 'separation of the
powers' meaning that nobody can be a member of more than one
of the three arms of government, no Cabinet member is allowed
to be a member of the Congress. In Britain, every Government
Minister must be a member of one of the two Houses of
Parliament and, if he or she is not already in the Parliament, then
he or she is made a peer (that is, a member of the House of
Lords).
 Although the American political system has a strict 'separation of
the powers', members of the Supreme Court (the judiciary) are
nominated by one of the other arms of government (the
President) and approved by one part of another arm of
government (the Senate which is part of the legislature). In the
UK, almost all members of the upper chamber of the legislature
(the House of Lords) are effectively chosen by the political party
leaders in the lower chamber of the legislature (the House of
Commons).

THE EXECUTIVE
 The United States is a republic with an elected head of state, the
President. In contrast, the United Kingdom is a monarchy with the
head of state being a hereditary member of the royal family
(although he or she has no real power but only a ceremonial role)
 The USA is a presidential system, with the apex of power in a
President elected indirectly through an Electoral College, whereas
the UK is a parliamentary system, with the Prime Minister holding
office and power so long as he or she commands a majority of
votes in the House of Commons.
 In theory then, the American President has much more power
than the British Prime Minister - he is the commander-in-chief and
has the power to issue executive orders which have the full force
of law. However, the constitutional system of 'checks and
balances' seriously circumscribes the power of the US President
who often finds it really difficult to push legislation through
Congress. By contrast, a British Prime Minister usually heads a
government with a majority of seats in the House of Commons
and the ability to pass almost any legislation that he or she
wishes.
 In the United States, the transition period between the election of
a new president and that person's inaugration is two and half
months. In Britain, the changeover of Prime Ministers is virtually
immediate - within hours of the election result, one person leaves
10 Downing Street and within the following hour the successor
enters it.
 A US President is limited by the constitution to two four-year
terms in office, whereas there is no limit to the time that a British
Prime Minister can serve in the office.
 In the US, government is highly partisan with the President
appointing to the executive colleagues who are almost exclusively
from within his own party. In the UK, government is normally
equally partisan with all Ministers coming from the governing
party but, in 2010, exceptionally the Conservatives were required
to go into a coalition with the Liberal Democrats and grant them
17 ministerial positions.
 The American Cabinet is appointed by the President but he does
not chair it or even attend it. The British Cabinet is appointed by
the Prime Minister who normally attends and chairs every
meeting.
 The size of the American Cabinet is fixed: it is the Vice-President
plus all the heads of the executive departments making a total of
16. The size of the British Cabinet varies: it is whatever size the
Prime Minister wants it to be which is normally around 18,
sometimes with a small number of additional Ministers who are
not actual members but who are invited to attend on a regular
basis.
 The American Cabinet meets at irregular intervals and acts as
adviser to the President. The British Cabinet meets once a week
and formally takes decisions, usually by consensus under the
guidance of the Prime Minister.
 In the United States, the incoming President and his aides make a
total of around 7,000 political appointments. In Britain, the Prime
Minister appoints around 100 members of the Government and
members of the Cabinet each appoint a couple of Special Advisers,
so the total number of political appointments is around 150.
 In the United States, all the most senior appointments are subject
to confirmation hearings and votes in the Senate. In Britain, there
is no procedural method of challenging the appointment of a
particular Minister although, in theory, the Opposition could move
a vote of no confidence in the appropriate House of Parliament.
 In the USA, after the Vice-President the Secretary of State is the
most senior member of the Cabinet and in many countries would
be known as the Foreign Secretary. In Britain, the political head of
each Government Department is called Secretary of State and so
almost every member of the Cabinet is a Secretary of State.
 In the United States, the incoming President's inaugural address is
a highly public and prestigious affair. In Britain, the new Prime
Minister simply sets out his or her vision for the country in a
speech to the House of Commons on the subject of the Queen's
Speech which opens the new session of Parliament.
 In the United States, the President each year gives a high-profile
'State of the Union Address'. In Britain, there is no equivalent
occasion, the nearest event being the Prime Minister's introduction
to the Government's legislative intentions for the next year or so
after the State Opening of Parliament each session.
 As a result of the separation of the powers, the US President does
not attend or address Congress except for the annual 'State of the
Union Address'. Since there is no separation of the powers in the
 UK system, the Prime Minister is a member of one of the Houses
of Parliament - these days, invariably the House of Commons -
and regularly addresses the Commons, most notably once a week
for Prime Minister's Question Time (PMQ). When the President
addresses Congress, he is given a respectful hearing. When the
Prime Minister addresses Pariament, he or she is barracked and
interrupted and Prime Minister's Question Time in particular is a
gladiatorial affair.

THE LEGISLATURE

 In the USA, both houses of the legislature - the Senate and the
House of Representatives - are directly elected. In the UK, the
House of Commons is directly elected, but the House of Lords is
largely appointed (making it unique in the democratic world).
 In the States, as a consequence of the separation of the powers,
all legislation is introduced by a member of Congress, so even the
signature legislation attributed to President Obama on healthcare
reform was actually introduced by a Congressman (Democratic
member of the House of Representatives Charles Rangel). In total
contrast, almost all legislation in Britain is introduced by the
Government with only a very small number of Bills - usually on
social issues with minimal implications for the public purse -
introduced by individual Members of Parliament (they are called
Private Members' Bills).
 Senate rules permit what is called a filibuster when a senator, or a
series of senators, can speak for as long as they wish and on any
topic they choose, unless a supermajority of three-fifths of the
Senate (60 Senators, if all 100 seats are filled) brings debate to a
close by invoking what is called cloture (taken from the French
term for closure). There is no equivalent provision for preventing
filibustering in either House of the British Parliament but
filibustering is rare.
 In both the House of Representatives and the Senate, the
majority party chairs all committees which have considerable
power. In the two chambers of the British legislature, committee
chairperships are allocated between the different parties, roughly
in proportion to the size of the party in the House, and the
committees are much less powerful than in the US Congress.
  In the House of Representatives, the Speaker - chosen by the
members of the largest party - has considerable power and acts in
a highly partisan fashion. In the House of Commons, the Speaker
- chosen by the whole House - only has procedural responsibilities
and acts in a non-partisan manner (usually he is not opposed in a
General Election).

THE JUDICIARY

 In America, the Supreme Court is an intensely political institution

- its members are appointed by the President on a partisan basis
and its decisions are often highly political and highly controversial.
By contrast, in Britain the Supreme Court is not appointed on a
political basis and, like all British courts, avoids making decisions
which it regards as proper to politicians and Parliament.
 In the United States, 39 states hold at least some competitive
elections to choose judges. When the country was first created,
there were no such elections (Mississippi became the first state to
require judicial elections in 1832). In the UK, no judges are
elected. Indeed very few countries worldwide have judical
elections. Exceptions including Japan and Switzerland.

POLITICAL PARTIES

 In the the USA, the Republicans are the Right of Centre party and
the Democrats are the Left of Centre party. In the UK, the
Conservatives are the Right of Centre party and Labour is the Left
of Centre party. However, the 'centre' in American political is
markedly to the Right of the 'centre' in British or most of
European politics. This means that the policies espoused by Tea
Party candidates would not be supported by any political party in
Britain, while the policies supported by an American politician like
Bernie Sanders, the Independent senator from Vermont, would be
mainstream in the British Labour Party.
 In the USA, there is no centre party in this sense of one
positioned politically between the Republicans and the Democrats.
In Britain, there is a Liberal Democrat Party which ideologically
sees itself as between Conservative and Labour.
 In the USA, there are only two parties represented in Congress
and both are federal parties; there is no political party that only
seeks votes in one state or a selection of states. In the UK, as well
as political parties that seek votes throughout the entire country,
there are nationalist political parties that field candidates only in
Scotland, Wales and Northern Ireland respectively.
 In the United States, the Democratic and Republican Parties
absolutely dominate federal and state elections with independents
securing only small proportions of the vote. In the United
Kingdom, the two main political parties - Conservative and Labour
- win a smaller and declining share of the total vote, with a
growing share being taken by the likes of the Liberal Democrat
Party and the UK Independence Party at national level and by the
likes of the Scottish and Welsh Nationalist Parties at the devolved
level.
 In American politics, the two main political parties are loose
coalitions with individual candidates or Congressmen adopting
varying positions on many issues (although, in recent years, the
Tea Party movement has forced Republican politicians to proclaim
more consistently conservative positions). In British politics, all
political parties have much tighter rein on the policies promoted
by candidates and the voting by elected representatives. (In the
House of Commons, each week a 'whip' is issued which sets out
how the Member of Parliament should vote on each major issue
before the legislature that week).
 The major parties in the USA have a large-scale congress every
four years to choose their candidate for the forthcoming
presidential election and ostensibly determine the policy platform
of that candidate. All the political parties in the UK hold annual
conferences where they debate the policy positions to be adopted
by the party, but these conferences do not choose the party
leader (which is done through a separate and broader process
varying from party to party).
 In illustrations and promotional material, the Democratic Party is
often represented as a donkey, while the Republican Party is
featured as an elephant - symbols that date back to the 1870s.
British political parties regularly change their symbols and very
few electors have any idea what they are.
ELECTIONS AND CAMPAIGNS

 In the USA, the term of a President, Senator or Congressman is

known precisely as four years, six years and two years
respectively and the dates of the elections are fixed. In the UK,
the term of members of the House of Commons - and therefore of
the Government - is legally a maximum of five years but
traditionally a Prime Minister could call a general election
whenever he or she wished and it has been considered 'cowardly'
to wait the full five years and so the election has been more
typically after around four years. However, the current Coalition
Government has enacted legislation to provide for a fixed five-
year term except for special circumstances.
 Candidates for the Presidency, the Senate and the House of
Representatives - plus a host of other positions below federal level
- in the US political system are chosen by a system of primaries in
which (usually) all registered Democratic and Republican voters
participate in the choice of the candidate for 'their' party in the
main election. Britain does not have a system of primaries and the
selection of candidates is normally confined to actual members of
the relevant political party in the constituency in question.
 The filling of vacancies varies between and within the two political
systems. The US Constitution states that special elections will be
held to fill vacant Senate seats, but that state legislatures may
empower the governor of the state to fill the seat by an
appointment between the time that it becomes vacant and the
time that the winner of the special election is certified. Most states
allow the governors to pick the replacement who serves until the
next general election when the voters decide who will serve the
remainder of the term. Several states, however, require that a
special election be held with the governor certifying the winner as
the Senate member. By contrast, the Constitution requires that
governors call special elections to fill a vacancy in the House of
Representatives. They are usually held within three-six months of
a vacancy because the entire election process must be followed:
nominating conventions or primary elections plus a general
election. In the UK, vacancies in the House of Commons are filled
by a by-election in the relevant constituency which is usually held
within three or four months. Since members of the House of Lords
 were not elected in the first place, there is no by-election when a
peer resigns or dies.
 The American general election effectively lasts almost two years,
starting with the declaration of candidates for the primaries. The
British general election lasts around four weeks.
 American elections depend on vast sums to purchase broadcasting
time. Parties and candidates in British elections cannot buy
broadcasting time.
 As a consequence of the Supreme Court decision in the Citizens
United case, effectively there are no limitations on expenditure in
American political elections. There are statutory limitations on
expenditure for all elections in the UK.
 In the States, almost 40 million television viewers watched the
Convention speeches of Barack Obama and Sarah Palin in 2008.
No party conference speech in Britain would attract more than a
few million.
 American presidential candidates have been taking part in
televised debates since 1960. British political leaders only agreed
to televised debates for the first time in the General Election of
2010.
 The first televised debate between Barack Obama and Mitt
Romney in 2012 attracted almost 70 million viewers. Even
allowing for the difference in population, the televised debates
between the British party leaders do not attract the same level of
interest.
 In an American presidential election, turnout is typically around
50% (although in the 2008 election it was over 60%) and, in the
case of mid-term Congressional elections, turnout typically falls to
around 40%. In the UK, turnout in General Elections used to be
around 75% but more recently has fallen to around 60%.
 In the USA, blue signifies states held by the Democratic Party, the
more left-wing. In the UK, blue identifies the Conservative Party,
the more right-wing.
 In the USA, red signifies states held by the Republican Party, the
more right-wing. In the UK, red identifies the Labour Party, the
more left-wing.
 In an American general election, the states that might go to one
party or the other are known as 'purple states' or 'swing states' or
simply 'competitive'. In a British general election, constituencies
 that might go to one party or another are called 'marginal
constituencies' (where three parties are each in contention - which
is not unknown - it is called 'a three-way marginal').
 American elections are often so raw and vitriolic that candidates
make spurious claims about themselves or their opponents that
need to be analysed for the truth and whole web sites are devoted
to fact checking. While British politicians are certainly not beyond
exaggeration or obfuscation, they are rarely guilty of the blatant
truth-twisting that one sadly sees in the US.
 American elections routinely involve attack advertisements which
denigrate one's opponent in highly personal terms and even
presidentual primaries can involve sharply derogatory remarks
about one's opponent in the same party (witness the Republican
primaries of 2016). It is unusual for election material in Britain to
attack an opponent in personal terms and virtually unknown in
televsion broadcasts (although a recent - and widely condemned -
exception was in the London Mayor elections of 2016 when the
Conservative candidate highlighted the religion of his Labour
opponent).
 In the United States, certain families have provided a number of
very promiment politicians: such as the Kennedys and Clintons for
the Democrats and the Bushs for the Republicans. Furthermore a
significant number of members of Congress are relatives of
someone who has previously served in Congress or high office.
Name recognotion is very important in American elections. By
contrast, in Britain sons (and sometimes daughters) have followed
fathers (or even mothers) into the House of Commons but less
frequently and less prominently than is the case in the USA. In
British elections, the party is usually much more important than
the individual.

STYLE OF POLITICS

 In America, the term 'conservative' means really right-wing,

especially on social issues. In Britain the name 'Conservative'
means mainstream right-wing, especially on economic issues.
 In America, the term 'liberal' generally means quite left-wing. In
Britain, the name 'Liberal' means broadly centrist.
 In the States, it is considered necessary for a politician to
emphasize their patriotism. In Britain, it is assumed that anyone
who wants to run for national office cares for his or her country.
 In the United States, the flag holds special place in the political
heart of the nation, people sing to it while placing a hand over
their heart, and many people would like to make burning it a
criminal offence. In Britain the flag is rarely prominent at political
events.
 In the United States, since 9/11 most politicians wear a pin
depicting the stars and stripes. In Britain, no politician would wear
a badge displaying the union jack.
 So many political speeches in the US include the phrase "my
fellow Americans". In British political terminology, there is simply
no equivalent phrase.
 In the States, virtually every political speech seems to mention
God, especially in the final call "God bless America". In Britain, no
politician mentions God and none would think of inviting Him to
show a special preference for his or her nation state.
 In the US, politicians frequently refer to their position on social
issues like abortion and homosexuality. A British politician would
think it unnecessary and inappropriate to talk about such issues
unless asked.
 In the US, politicians constantly talk about the problems and the
aspirations of the middle class. In the UK, politicians tend to talk
more about the needs of the working class. They mean something
similar but the language is different because the perceptions are
different. In America, the working class is seen as the poor and
most citizens perceive themselves as middle-class or aspiring to
be so. In Britain, the middle-class is seen as a comfortable
minority with the majority of the population perceiving themselves
as working class.
 Although taxes are never popular, the issue of taxation is much
more emotive in American politics than in British (or European)
politics and the terms of debate on taxation are much more
hostile. The United States was born in a revolt against paying
taxes and many Republicans are against any tax increases and
believe that low taxation stimulates economic growth, whereas
many British (and European) politicians see taxation as a social
 instrument as well as a fiscal one with the power to bring about
redistribution in society.
 American political speeches do not tend to make much use of
facts and figures (those of former President Clinton tend to be an
exception) but appeal more to broad values which do not lend
themselves to quantification. Many British political speeches focus
on practical issues and use figures to highlight problems and make
comparisons with the policies or the performance of one's
opponents.
 In the States, there are currently some outstanding political
speakers, led by Bill Clinton and Barack Obama. In Britain, there
is no politician who can be so inspirational, although Tony Blair at
his best came close (but he's gone). On the other hand, British
politicians tend to be better debaters because of the more
confrontational style of discussion in the House of Commons,
especially Prime Minister's Questions.
 In US political theory and discourse, there is a notion called
'American exceptionalism'. There are several versions of this
nebulous concept, perhaps the most common being that the
United States has a special 'superiority' in the world because of its
history, size, wealth and global dominance plus the 'sophistication'
of its constitution and power of its values such as individualism,
innovation and entrepreneurship. Many American politicians refer
to the USA being "the greatest country on earth" or even "the
greatest nation in history". Although Britain fairly recently ruled
over the largest empire in world history and has other claims to
'greatness' - not least its political system and cultural reach -
there is no concept in British political discourse which compares to
'American exceptionalism'.