A way of comparing the US and UK systems of government is by using three theoretical approaches.
Rational, Structural and Cultural
The Rational Choice Approach theorises how individuals behave to maximise their own best interests- so it might be thought of as the 'selfish' model or consumer model. By acting rationally, individuals judge how best to achieve their aims. These aims may be winning or maintaining power within a political system or attempting to achieve ideological or policy goals. This approach is most useful when applied to a comparison of individuals within political systems such as presidents, prime ministers (PM) ministers , legislative politicians and voters.
People act in ways which they think are best for them
It assumes that individuals act in a rational, logical way in order to maximise their own self-interest. They choose what rationally will be best for themselves — hence the term rational or ‘rational choice’. This approach presumes that each individual has their own set of political goals and they will make decisions based on the best way to achieve those goals. A rational approach suggests that individuals will act rationally, choosing to act in a particular way so as to give them the most beneficial outcome.
Politicians know that this is true of voters, at least to some extent. so when Ronald Reagan in his televised debate with President Jimmy Carter in 1980 posed the question to voters, ‘Are you better off than you were four years ago?’ he was appealing to their rationality and self interest. This view sees the voter as a savvy consumer who is shopping for the best party, policy or politician.
That said, this approach is not without its critics, particularly in understanding voting, who believe that it overestimates human rationality- think of the shopper again and we know that we all make emotional choices and buy things we don't need. The rational choice model also ignores the difficulty of the ordinary individual gaining the accurate information required to make such ‘rational’ choices. It's hard to view voting for Trump as simply 'rational'
When using this model to compare the power of the president and they both act in a rational manner, using their own powers to achieve their policy goals. Both the president and prime minister have considerable authority as leaders of the government to set a political agenda for the country, based on their personal views or self interest. They also have power, particularly within the executive, to appoint people to key decision-making positions. It was probably self interest which motivated Theresa May to appoint Boris Johnson to her cabinet. President Johnson LBJ famously observed that it was better to have a rival ' In the tent pissing out, rather than, out of the tent pissing in'.
When comparing the power of a Congressman and a Member of Parliament (MP), both might vote in Congress or in Parliament, acting rationally to maintain their own position of power. They will have rational considerations of getting re-elected, but the MP may be more motivated by the possibility of promotion up the 'greasy pole'. They might resist structural and cultural factors. Members of Congress and Parliament might ignore executive patronage-power or the dominant view of their party because they are trying to maintain their own chances of re-election by pleasing constituents or visa versa they might ignore their constituents in the interest of their own career in the party or government.
The rational approach might explain that US voters are more likely to pursue their own rational self-interest than UK voters since the separation of powers means Congress members, being less controlled by party and government are able to use legislation to benefit their constituents though 'Pork' and 'earmarks'. It make rational sense for voters in the USA vote for incumbent politicians sine they are most likely to provide or have provided Pork.
A cultural approach looks at how we are influenced by the groups we belong to, such as political parties, pressure groups, factions or groups of voters. It suggests that people operate as they do because of the culture of the group they are in. The group culture is the shared ideas, beliefs and values — to which members conform, and which influences individual members' actions. While individuals often choose to join a group, this group can still influence or restrict their behaviour. Culture is habitual and perceived as natural, giving it power over individuals that they may not be aware of. For sociologist ideas such a socialisation or group think explore these effects.
· Comparing the prime minister and president using a cultural approach it might be suggested that they may alter their policy goals because of the culture of their party which might happen if their own views are out of step with the views of their party and the prime minister or president feels the need to adjust their aims. While this is possible it is quite hard to think of examples- Clement Attlee was no great socialist but presided over a programme of nationalisation which was the policy of the Labour Party but PMs and President have reached the top of the system so tend to lead policy and at least try to set the culture of their party. Eg Blair and New Labour. However, politicians can find themselves influenced by the culture of the establishment which leads them in to conflict with their party- The party of government can be rather different to the party of opposition as they find a culture of pragmatism prevails in the corridors of Whitehall. In other words the culture of the civil service may be more influential than the party. In the USA the term 'Going Native' is used to described politicians who have become sympathetic to the culture of their departments.
A study of comparative politics through a cultural approach also focuses on the prevailing political, social, economic and religious ideas within each nation. For example in the UK Conservatives are very different to Conservatives in the USA and in the USA Republicans form the Northeast ate very different from Republicans form Texas. Culture can be defined as a shared, learned and symbolic system of values, beliefs, ideas and attitudes that shapes and influences people’s perceptions and behaviour. It tells us who we are collectively, what is important to us, and how we should behave — as Americans or as citizens of the UK. Culture must be collective; there is no such thing as a culture of one. By definition, culture is shared among members of a community. So a cultural approach to politics suggests that shared ideas, beliefs and values often determine the actions of individuals and groups within them. This is used to explain voting behaviour in terms of class and partisan alignment- Why are inner cities in the UK more likely to be Labour and the rural Midwest more likely to be Republican? It is suggested that this is regional culture and tradition. But again this is hard to separate from rational self interest since Labour governments are more likely to pursue policies which will benefit inner cities and the Republican more likely to be support agriculture.
There is also a Marxist perspective which sees culture as shaped by the dominant class and the nation’s elite and therefore merely reflects the cultural ideas of those elite. ' In every age the dominant ideas are the ideas of the dominant class'- Marx. But this does acknowledge that culture influences behaviour even if it is as a form of control.
Culture can explain why individuals and societies act and behave in certain ways. It can explain how they react to safeguard what they see as the fundamental rights and liberties of their nation — to safeguard ‘their way of life’. It can explain why people vote in a certain way, take to protest marches or movements, or fight for causes. Culture has a power to motivate people and to shape society, to create far-reaching change or to preserve the status quo.
There is a stronger culture of 'freedom as an ideal. Most American share some idea of state-rights and individuals right protection and therefore greater desire to respect state power and limited government. governments. This culture of individualism is dominant in the US, so most politicians conform to this cultural expectation. Similarly there is a shared religious culture in the US which mean that moral issues become political issues.
Cultural explanations could also be used to examine the level of rights protection. The US has a culture of legalism which means rights tend to be expressed in law and with stronger structures to protect rights than the UK, but rights are still well protected in the UK despite the lack of an entrenched bill of rights and sovereign constitution. In the UK there is a culture of Common Law and negative rights. There are cultural expectations of rights protection, within parties and the country. In proposing the right to gay marriage, David Cameron was responding to a dominant cultural belief of equality. This might suggest that the structural approach is central to understanding the US Constitution, where everything is laid out in a single document, while in the UK the cultural approach is equally important.
The structural approach focuses on the institutions in a political system and the processes within them. A structural approach suggests that political outcomes are largely determined by the formal processes such as how laws are made, how elects are organised, how legislatures and executives are structured. Structures create particular relationships, such as between the government and legislature and between government and the governed between the party establishment and party members, or between pressure groups and their members.
The structural approach can be applied readily to all topics because major political structures, such as how constitutions, influence or determine political processes in every area.
· Comparing the prime minister and president using the structural approach, the constitution creates very different structures in the UK and USA. Many US presidents have envied a British PM control over Parliament and many PMs might wish for the control presidents have over their cabinets. . Both presidents and prime ministers have seen some of their key policy goals restricted by court decisions.
· Looking at politicians in Congress and Parliament, they have different levels of power from each other. Arguably, UK MPs are more limited because of the fused constitution (legislature and executive are fused)which creates a parliamentary system whereas the USA has a separation of powers. This means US members of Congress have a greater ability to act as they wish because there is less pressure from the executive (president).
Constitutions of the UK and USA
The structural approach is the most useful form of analysis. Constitutions are structures that affect so much of the rest of the political system and help to explain the main similarities and differences between the UK and US systems.
Codification and entrenchment
The main function of a constitution is to set out the rules of the political game, by regulating the powers, roles and limits of all individuals and institutions involved in the political process. One fundamental structural difference is that the US Constitution is codified and entrenched, while the UK constitution is not.
The consequences of this are:
The courts are far more powerful in the USA than the UK
Politicians and citizens are more likely to seek solutions to political problems in the courts in the USA than they are in the UK.
Politics in the USA tends to operate within constitutional limits and there is a consensus on the correctness of the constitution- so parties rarely offer radical change. In the UK Parliamentary Sovereignty offer the possibility of a legislative revolution. This is one reason there is no main stream party of the socialist left in the USA.
Separation of powers
The fusion of powers in the UK provides the basis for greater executive domination. The parliamentary system means that the prime minister must command a majority in the House of Commons — a majority they can deploy to achieve their policy goals. US presidents are often in a situation where they lack a congressional majority, so are more subject to legislative opposition than a prime minister. Also, Congress and the president can claim an equal mandate and right to govern, which creates 'an invitation to struggle'. The awarding of a mandate in the UK is usually claimed by the winning party in government, in which the prime minister claims a right to put manifesto promises into practice.
The Sovereignty of Parliament means the executive dominates the legislature ( most of the time)
This means lobbying Parliament is far less effective for Pressure groups in the UK than pressure groups in the USA.
Devolution and federalism
There are multiple access points for pressure groups in the USA- which can influence through local government, states and the three branches of the federal government. In the UK devolution has created more opportunities for pressure groups influence but the more significant location of power remains in the UK government.
Devolution in the UK means that the power of regions is less protected than in the federal US. To reduce the power of a region in the UK, the House of Commons requires only a 50 per cent plus vote; in the US, a more difficult constitutional amendment is required. This is not to say that the level of regional power has to be higher in the United States. Federalism does not necessarily give regions greater power than devolution does, but simply protects that regional power from the central government. However, currently the UK constitution does award less power to regions than the US Constitution does.
Federalism is supposed to ensure greater protection of regional power, but whether it succeeds is open to question. In the US, the federal government and the Supreme Court have gradually allowed significant erosion of state power. In the UK, the structure of parliamentary sovereignty allows for the reduction of the power of devolved regions, including the Welsh or London Assembly.
Checks and balances
Both political systems provide checks and balances, with legislatures able to provide checks on the executive branch (for example, through voting on their legislative proposals). The UK's fusion of powers limits the effectiveness of checks and balances due to executive domination of the
legislature. By contrast, the US president and Congress are interdependent; each finds it difficult to act without agreement from the other.
In the UK, while Parliament can vote against the government, checks and balances are not particularly powerful. Power tends to be concentrated in the hands of the government or prime minister, and the powerful whip system and patronage ensure a loyal majority in the Commons.
The US Constitution provides extensive checks and balances, which prevent such executive domination. The president lacks ongoing patronage power. Members of Congress, even within the president's own party, may be more loyal to constituents than to their own party leader.
Location of sovereignty
This has a major impact on the relative power of the US and UK judiciaries. The UK Supreme Court is significantly weaker than its US counterpart, because UK justices have no codified constitution to uphold and cannot declare acts of Parliament to be unconstitutional. However, in the US the Supreme Court can overturn acts of Congress.
Both political systems have strong mechanisms for rights protection, but it could be argued that the US Constitution provides much stronger protection than the UK constitution. The sovereign entrenched Constitution means that individuals can challenge powerful institutions that restrict liberty. There are many cases of individuals and groups protecting their rights in the US. In the UK, those rights are more vulnerable to executive and parliamentary attack, partly because they can be amended or overturned with a new Act of Parliament.
There are many counter-arguments that rights are not necessarily better respected in the US. Despite the lower level of structural protections, the UK has shown a relatively high level of rights protection. In the US there have been a number of rights concerns, including concerns about the power of the US security state after 9/11 (exemplified by the creation of the Guantanamo detention camp) and continuing major concerns about the rights of racial minorities.
The amendment process
The amendment process provides a much stronger structure in the US than the UK, restricting politicians more because they find it harder to change the rules of the political game. In the UK, any judicial interpretation can be overturned by a new Act of Parliament. If the government dislikes the way a law has been interpreted, it can easily change it. In the United States, the courts have the power of judicial review, through which they can overturn the actions of any institution, including Congress. The entrenched constitution means that their decisions are unlikely ever to be overturned by politicians.
Legislatures: Congress and Parliament
According to Nelson Polsby the structure and culture of Congress and Parliament means they can be classified as quite different forms of legislature. The British Parliament differs from the US Congress in that its House of Commons is an “arena” assembly and not a “transformative” assembly. This distinction was made by the American political scientist, Nelson Polsby, who divided legislative assemblies into two types. “Transformative” assemblies like the US Congress take into the assembly in the persons of the members of Congress the pressures from society and then themselves shape and mould legislation. Bills are often named after the Congressmen and women who had really made the legislation. “Arena” assemblies like the British House of Commons do not make laws themselves but are arenas where contending groups fight it out. They provide locations for a contest, like a sports arena or bull-ring. They are not corporate institutions or formal organisations with their own legal personalities. They hold ministers to account. They influence Government policy and legislation, exercising most influence by the “rule of anticipated reactions”. This law of political science is that Governments think ahead when making their policy and legislation, and try to anticipate the likely reactions of the MPs. So the Commons exerts considerable influence over the Government since the Government does not want to bring forward proposals that will incite strong opposition from MPs. They usually correctly anticipate the likely reactions of the MPs so that their proposals usually sail through the procedures of the Commons with little significant change being made.