3/19/04

Assess the Relative Merits of the French and American Presidential Systems

The French and American Presidency both hold similar positions and roles. For example, both are Head of State, Chief of Executive, Chief Diplomat, as well as Commander in Chief of the Army and Navy. In order to evaluate the relative merits of these Presidential systems we are going to evaluate how much each president is able to employ for each position and how effective they are at doing so. To do this the differences in their constitutions have to be examined. For example, the American Constitution attempts to restrict the President in order to encourage stability and prevent abuses of control. On the other hand, in France the Fifth Republic’s Constitution reinforces the authority of the President so that policies can be put through effectively in the National Assembly.

The Fourth Republic was dogged by a weak executive, with the National Assembly constantly getting bogged down by petty squabbles, leaving it both weak and unrepresentative. For example, in the twelve years of the Fourth Republic there were 25 different governments, as political infighting made it impossible to meter out any stable coalition, with the president spending much of his time trying to hold together the parliament. Wright claims the difficulty in parliament choosing a president meant that “they were seen as the creatures and prisoners of the members of parliament who had elected them and who, when choosing the president, had sought to avoid the election of a strong personality – a man who might prove a danger both to the privileges and prerogatives of parliament and to the republic itself”[1]. For example, it took Rene Cote, the last president of the Fourth Republic thirteen ballots in order to get elected, a waste of time and a battering to any political leader’s prestige. It is also put across that any “presidential power was exercised only so long as it was tolerated by parliament and the government”.[2]

These factors resulted in France’s inability to deal effectively with any major events, such as the uprisings in Indochina (1954) and Algeria (1956). This is highlighted by Roskin who points out that people saw the Fourth Republic as “unable to settle the ghastly Algerian War”[3] and views that “if a premier was too effective, other politicians sometimes vote against him out of resentment”[4]. To prove this he cites Pierre Mendes’ dismissal from the National Assembly as being an example of jealousy over his success at dealing with the Indochina uprising. Williams proposes that as a result of all this infighting government even became unrepresentative, operating “with no reference to the general public”.[5]

The 1958 Constitution of the Fifth Republic was created in order to readdress these major flaws in French politics. Charles de Gaulle, the first President of the Fifth Republic was given new powers which enabled him to appoint and dismiss the prime minister and ministers without consultation. Similarly, the President was solely responsible for the Council of Ministers, the backbone of French bureaucracy and the key positions in the Judiciary. Successive Presidents have been able to exploit their influence, described by some observers as an “elected monarch”, with Wright suggesting that the office has “been much more powerful, more interventionist and more political than the constitutional texts appear to imply…in order to increase the scope of each of their functions”.[6]

The constitutional reforms appear to have succeeded in their aims. France is no longer the subject of international derision that she was in 1958 and the public is content, with Wright asserting that there is “a high level of satisfaction with the regime.”[7] However, the most important success of the Presidential reforms has been its stability. Prime ministers now enjoy longer periods of office and parliament is now prepared to work with the President. Even the army, something once described as “the state within the state”[8] during the previous regime has now been “reduced to silent obedience to the civil authorities.”[9] The President, unlike before is now the major political focus within France. Actions such as de Gaulle’s devaluation of the Franc in 1968 or Pompidou’s extensive industrial policy could not have happened without these new powers.

These reforms are not perfect however. For example, even though the President is able to dissolve the National Assembly constitutional checks result in him being only able to do it for only a couple months and only once a year. The French President is constantly constrained by time because of the high level of public ceremonies and political management. For example, if the French President attempted to get involved in every detail of legislation he would end up failing to guide sufficient policy. If for whatever reason the President was engaged, in the absence of the leadership the unguided ministers would most likely display “the sense of and purpose of freshly decapitated chickens”,[10] as Wright puts it. On the contrary, a President who failed to get involved in the bureaucracy would be held hostage to the “overloaded, defective and inefficient”[11] civil service, resulting in the President’s requests not fully being implemented.

There are other restrictions that have a more significant ability to influence the President and his action. Wright argues that France has “different ‘unofficial’ types of power”.[12] For instance, it was a small group of communist-led workers, grouped in closed shops, who shut down the port of Le Havre for many weeks and who, on several occasions between 1975 and 1977 brought the Paris press to a standstill. Increasing EU integration over political, economic and even cultural matters is decreasing the President’s a scope of autonomy. For instance, the President has relatively little influence over the Euro compared to what he did with the Franc.

The roles and power are far more complicated for the American President. The Constitution of 1787 was created in order to ensure that no man or state had too much control over the Federation, whilst simultaneously ensuring that the President had enough power to defend the country in times of war. Consequentially the President and Congress are constantly at odds with each other. Wilson summarises it by mentioning that “no policy, domestic or foreign, can be maintained effectively by a President without the approval of Congress in the form of laws and money; and second, that there is no way under our Constitution for a President to force Congress to pass a law or spend money against its will”.[13] The complexities of the Constitution mean that no single centre of power can act alone in restraining the President. They form a close network which can be very strong against unruly Presidential actions. However, as Rossiter points out, these rules are not designed to paralyse him, merely to reinforce his boundaries, “if he cannot judge the limits of his power, he cannot call upon its strength. If he cannot sense the possible, he will exhaust himself attempting the impossible”.[14] In the example Rossiter gave the public was in uproar arising from the seizure of the steel mills, eventually forcing Truman to back down in 1952. In order to balance all these pressure groups the President is most likely to “dissipate all his time, energy, and capacity for leadership”,[15] to an even greater extent than the French Presidency, as he has to deal with many aforementioned groups.

The President does still hold some significant control. For instance, Wilson highlights how Carter and Reagan selected most of the federal judges now on the bench, stamping their political philosophies on the courts. Rossiter raises an interesting point when it comes to the President’s role as representative of the people. He highlights how despite lacking a Congressional majority, a President with popular support is “expected by the country, and therefore by Congress, to turn his politics into law”.[16] However, as he points out later it is “only if he uses it in ways they understand and approve, which generally means ways that are fair, dignified, traditional, and familiar. He can lead public opinion, but only as far as public opinion is willing to go”.[17]

The Constitution gives significant powers to the President in terms of international affairs. Congress relaxes its bite in times of war, believing that any conflicts would be distracting and counterproductive. Truman went far enough to suggest that in terms of foreign policy the Presidency forms “an aggregate of power that would have made Caesar or Genghis Khan or Napoleon bite his nails with envy”,[18] reiterating it by claiming that “no man or combination of men in the United States can muster up so quickly and authoritatively the troops, experts, food, money, loans, equipment, medical supplies, and moral support that may be needed in a disaster”.[19] Wilson even went so far as to call it an “Imperial Presidency”.[20] In order to highlight the President’s strength he shows how Kennedy and Johnson were able to send American troops to intervene in Vietnam. Hamilton argues that as Chief Diplomat the President has great authority, suggesting in regard to Eisenhower “the President has repeatedly committed the nation to decisive attitudes and actions abroad, more than to war itself…a stubborn President is hard to budge, a crusading President is hard to thwart”.[21] Even though Congress is required to rubber stamp any wars, the President’s position is paramount with foreign policy. This is, as Rossiter puts it, partly because the President’s short-term actions create long-range consequences.

As Commander in Chief of the Army and Navy the President has control of maintaining the forces and making key decisions, such as whether or not to deploy nuclear missiles. Rossiter cites how this role can create a lot of flexibility in periods of war through ginger reinterpretations of the role, such as Roosevelt’s evacuation of Japanese citizens during WWII. Infact, he even goes so far as to claim that Congress is “more likely to needle the President for inactivity and timidity than to accuse him of acting too swiftly.”[22]

However, the Presidency does still have problems associated with this degree of power abroad. As Commander In Chief he supervises the forces and is “accountable to the people, Congress and history for the nation’s readiness to meet an enemy assault”.[23] The President still has to make treaties with the Senate and they have stood up to the President on major issues. For example, Carter’s anti-arms limitation treaty with the Soviets was blocked by the Senate and Reagan was never allowed to test anti-satellite weapons.

Both nations constitutions have succeed in their respective roles. The French have a strong Presidency which maintains order, whereas the American model favours stability and independence to perfect efficiency but still empowers the President on the world stage. Domestically, France’s President is far more powerful. America’s domestic political framework is generally too complex to implement bold policies that the French have previously initiated. However, France’s growing integration with Europe should clip the President’s wings both domestically and internationally, as he will have to follow a more conformist policy in the future. Internationally America is politically, militarily and economically superior. As a result it would have been impossible for France’s President to have (and have gotten away with) invading Iraq despite the international communities loud disapproval.


This article was written by Jonathan McHugh in March 2004

[1] Wright, Vincent The Government And Politics Of France (Hutchinson, 1984) p20-23

[2] Ibid. p22

[3] Roskin, Michael J Countries and Concepts: An Introduction to Comparative Government (Prentice-Hall, 1982), p91.

[4] Ibid. p91

[5] Williams Philip M The French Parliament (George Allen And Unwin, 1968) p114

[6] Wright, Vincent The Government And Politics Of France (Hutchinson, 1984) p28

[7] Ibid. p293

[8] Ibid. p293

[9] Ibid. p293

[10] Wright, Vincent the Government and Politics of France (Hutchinson, 1984). p295

[11] Ibid. p295

[12] Ibid. p298

[13] Wilson, James American Government (DC Heath and Company, 1989) p36

[14] Rossiter, Clinton The American Presidency (Hamish Hamilton, 1957). p36

[15] Ibid. p41

[16] Ibid. p47

[17] Ibid. p48

[18] Rossiter, Clinton The American Presidency (Hamish Hamilton, 1957). p16

[19] Ibid. p20

[20] Wilson, James American Government (DC Heath and Company, 1989) p315

[21] Rossiter, Clinton The American Presidency (Hamish Hamilton, 1957). p10

[22] Rossiter, Clinton The American Presidency (Hamish Hamilton, 1957). p13

[23] Ibid. p11

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