Comparison: Elections UK & USA

There are a few obvious similarities between elections in the  UK and elections in the USA. Both  use the First Past the Post voting system and both are largely winner take all. Both have two dominant parties  and both have representative legislative assemblies with the election of represenatives from single member constituencies.

However, a more detailed comparison shows many significant structural differences.

A UK general election is an election for one house of the national legislature, while the US ‘general election’ every four years has the election of the president, the whole of the House of Representatives, one-third of the Senate as well as many state and local officials. 

There are no mid term elections in the UK, no primaries and no caususes. Most significant of all is that the US is a presidential system while the UK  is parliamentary. Overall the underlying stuctural difference comes back to the constitution and in particular the separation of legislature and executive in the USA and the fused legislature and executive in the UK. The consequence of this is that the USA separates elections for the President and Congress while in the UK the government is formed from parliament. This means that PMs have no personal mandate and can be replaced without the need for an election. For example, Boris Johnson replaced Theresa May in 2019. A further constitutional difference is that the USA has a federal system while the UK has a largely unitary system. This means that federal elections in the US are run by and through the states resulting in the use of an electoral college. Another consequence of the federal system is that there are far more elections in the USA than in the UK. A typical UK citizen might have the opportunity to vote in elections of four or five kinds in their lifetime; general elections, local elections (district and county or simply unitary), maybe a mayor, possibly a referendum (these are rare), a devolved election (depends where they live) that might vote in elections for a Police and Crime Commissioner and not EU elections. Contrast this with the average US citizen who may vote in federal, state and local elections including; presidential, congressional, (House and Senate), primaries or caucuses, state legislature (bicameral in most states), governor, mayor, city hall, school board, sheriff and many more elected offices as well as state referendums, initiatives and possibly recall elections. The USA is therefore far more democratic than the UK in terms of opportunities to participate in elections.

Voting Systems

While both the US and UK use FPTP for general elections the UK makes far greater use of PR in devolved elections. Scotland and Wales use AMS, and N Ireland uses STV. PR systems are also used for London Assembly and Mayor. While two states — Maine and Nebraska — award their Electoral College votes based on the vote in each congressional district with the two remaining votes going to the state-wide winner. But although this can lead to a split in the electoral vote within the state, this is still really a winner-take-all contest. Then there are the presidential primaries in which the delegates to the party’s national convention are awarded on a proportional basis, rather than a winner- take-all basis — all but a few Republican primaries are still winner-take-all. But these are primaries — they are choosing delegates, not electing people to office.

As a result of the progressive movement at the beginning of the twentieth century and in opposition to the party machines of that era, the Proportional Representation League of the United States was formed. But even the League was realistic and pushed for reform of local elections at the city level rather than expecting any change at the state or federal level. Several cities — mainly in the Northeast — jumped on the proportional representation (PR) Bandwagon. But the biggest boost to PR came in 1936 when New York City adopted it for its city elections. Certainly, PR had many of the desired effects: a closer correlation between votes won and seats gained; an increase in women and ethnic minority candidates and office holders; and greater representation of third parties. But it was the onset of the Cold War and the Red Scare that led to the end of PR, as Communist Party candidates began to win seats on the New York City council, and by the end of the 1950s, the experiment had been abruptly halted, never to be repeated.

The United States electoral system is certainly the product of the nation's culture, and the vested interests of the state Democratic and Republican parties have resisted any change which might undermine their dominant position. This largely explains why the US Ppersists with the Electoral College system, despite the results of 2000 and 2016, and the way it has always distorted the results. This is a result of a two-party culture in the US and the rational self-interest of the two main parties. As can be seen in elections for the US House of Representatives in which candidates of the two major parties regularly win over 95% of the votes, the correlation of votes to seats has, historically, been quite close even with a winner-take-all system. But since the reapportionment following the 2010 census, this difference has risen to around 6 percentage points. In 2012, the Republicans won a 33-seat majority in the House despite winning well over 1 million fewer votes than the Democrats. This can almost entirely be explained by a deliberate policy of gerrymandering in Republican-controlled states.

In Senate elections the voting system was designed by the Founding Fathers to be undemocratic. It was not until 1910 that popular elections were used in Senate elections, until then Senators were appointed by state legislatures. Elections are staggered over a 6-year cycle with only 33 or 34 states voting in any one cycle. But the fact that Wyoming has two senators to represent its fewer than 600,000 inhabitants, as does California to represent its almost 40 million,has a profound effect on the ‘fairness’ principle in terms of votes to seats. But the over-representation of the small-population states in Senate is tied in with the history and culture of the nation. The fact that the folk of Wyoming and Alaska, and of North and South Dakota, have no incentive or intention to make a change is an example of the rational choice theory of politics in which individuals act in a way that achieves the best outcome for them. 

The fact that five electoral systems are still used in the UK reflects the organic and evolving culture of the nation.  In a sense the UK Constitution is always a work in progress while the US Constitution is viewed a complete document of unique genius which should be rarely tampered with.

The electoral systems devolved to Scotland, Wales and Northern Ireland, and to London were aimed to more reflective the cultures of those areas.For example, the single transferable vote system was adopted to give voice to the different cultural traditions of Northern Ireland, and the additional member system to do the same in Wales and Scotland. However, there was arational choice motivation as well since the Labour Blair government also hoped to ensure divided governments in Wales and Scotland which would not become strong centres of power and therefore models for independence. This objective largely failed in Scotland with the unexpected dominance of the SNP.

The way the first-past-the-post system operates in electing members to the UK House of Commons is also highly unfair and cements the two main parties in a dominant position. In the six elections between 1997 and 2017, the correlation between votes and seats for the three main parties was very unfair. In 2001, Labour won over 62% of the seats on a vote of just over 40%, while in 2010 the Liberal Democrats won nearly a quarter of the votes yet won less than 9% of the seats. The position of minor parties was, attimes, even worse. In 2015, the Scottish National Party polled 1.4 million votes but won 56 seats, while UKIP polled just under 4 million votes and won just one seat.

So how does the same electoral system produce a House of Representatives with just two parties but a House of Commons with 11? The main reason has to do with the cleavages within the two societies and the nature of the two-party systems. In the USA, the two major parties from the 50 states come together to field candidates across the nation for election to put it simply, the USA is not made up of four countries. The United Kingdom is. The electoral system reflects the structure and culture of the nation. However, there were rational motivations for the Labour Blair government to choose PR for Scotland and Wales since it hoped to ensure a weak and divided government which would avoid a rival regional power and not become a model which might encourage independence.  This aim failed in Scotland with the unexpected dominance of the SNP. Voting reform or the lack of reform tends to be guided by rational self-interest rather than democratic idealism. There is of course no 'best' voting system as they all have negative and positive consequences and may be judged differently according to who is judging them. 

Often we are asked to judge which system is ‘best’, but that depends on what we want from an electoral system — strong governments, stability, diverse representation, fairness?