Prime minister vs president

And in France, a prime minister (any minister, in fact) is plainly barred from being a member of parliament, and must resign his seat if he happens to be.

The PM being the leader of the majority again isn’t a feature of the parliamentary system in general, but a feature of the British system.

I think his dad was smart, although rather creepy. Clinton was an Oxford scholar, Obama’s smart. Most of them are smart but when it comes to inheriting the post you get the same problems monarchies everywhere have had… you can get lumbered with a nutter.

I bet it is generally easier to get rid of a prime minister than a president. A coalition party can withdraw, with the result being the need to call an election. The prime minster can dissolve parliament and call elections. There is the vote of confidence in parliamentary systems, but not presidential systems.
Generally prime ministers stay at the helm shorter. Presidents are not removed unless by impeachment and that is because of serious violations of the law.

Presidential systems have one fixed elections date, and if the president dies or resigns or impeached, his/her Vice President takes over until election date. But parliaments can call snap elections.
The president can’t be fired because there is not higher up, but a prime minister could be fired by the head of state, which is either the monarch or a ceremonial president. Most recent example is Iraq, where the president, Fuad Masum fired the prime minister, Nouri al-Maliki despite his party winning the general elections.
This does not occur often.
By the way there features of both system is not really only an “American” or “British” or “Canadian” system. Canada and Britain are not really unique from other parliamentary systems. And the U.S is no different than other presidential systems such as Brazil.

When was the last time you had a government shutdown?

Answer: Never. That’s because it’s almost impossible for a parliamentary system to get as gridlocked as a presidential system.

See:

http://www.cbc.ca/newsblogs/politics/inside-politics-blog/2013/10/government-shutdown-could-it-happen-in-canada.html

A third party does create risk of gridlock. Are you sure you don’t want gridlock?

Is an occasional government shutdown enough reason to say the US constitution is a bad one? Not quite. I think the main weakness of the US system is lack of responsible government. If the economy tanks in the next year, who do we blame, when government has a party split? It’s not clear. It’s true that a coalition government can have the same defect.

P.S. Someone mentioned France. They have an intermediate parliamentary/presidential system.

No necessarily, I thought the US had a disturbing habit of shooting theirs.

The key difference is that is that with a PM you are replacing the head of government.
There are usually several democratic ways of doing that, often with alarming speed.

Replacing the head of state more likely involves constitutional questions or a coups.

Not really.
Exhibit #1 Dismissal of Whitlam government 1977.
Cause: Refusal by one arm of government to pass the Supply Bill/budget of the other.

Yes, the US seems inclined to go to or over the cliff edge more frequently, be it over the budget, or debt ceilings etc. I couldn’t name another presidential model which has the same tendencies.

The primary difference is ideological, not the system of government. In the US a fair proportion of the political spectrum thinks shutting down the government is a sound strategy at any time. Hence the requisite brinkmanship becomes passe’.

Was the Whitlam/Gough crisis a shutdown, though? The Senate shot down the budget, and the Governor-General sacked the PM and appointed one who had the confidence of the Senate and the House, who, later, was elected in a general election. Putting aside the constitutional controversy of the GG’s action, it seems the matter was resolved fairly swiftly.

Let’s first correct my inexcusable mistake. The Whitlam Government was dismissed on 11th November 1975, not '77. :rolleyes: [smeg]

Did the money run out. No.

The Senate deferred the Supply Bills on 17th October.
Supply was formally going to conclude on 30th November.
So it was nearly a month as departments progressively ran out of cash. They were juggling and deferring capital expenditure, projects and salaries.

Kerr blinked.
Whitlam wasn’t going to.
Fraser wasn’t either, though the resolve of is Senate colleagues may have. One of those imponderables.

I was thinking of Canada, but you are right. Australia had one. The reason is a powerful branch of government, the Senate, elected independently of the lower house that elects the prime minister, and that can block supply. Although Australia has a mostly parliamentary system, allowing the Senate to block supply (budget) violates the concept.

I realize it was ugly, and the Governor-General didn’t cover himself with glory, but there is a system in place for dealing with lack of supply (Governor-General).

What commonly happens, in presidential republics, is that paralysis is resolved by a military coup. The US fortunately has different military traditions, so shutdowns are allowed to actually take place.

Aside from mixed presidential/parliamentary systems like France, Poland and Russia, in what parliamentary systems is the PM not the leader of the party that commands a majority in the House?

That’s certainly a feature of non-British parliamentary systems like Germany, Italy and Israel.

So do they take instructions from the General Secretary of their parties, and are just leaders of the government in the Assembly?

Yes but coups are only possible in dictatorships, I think this thread is about democracies even though the OP has not said it outright.
You are correct, but I just have to mention that in countries like Brazil, Chile, United States, Mexico and South Africa, the president is both head of state and government.

The situation in Portugal, a parliamentary democracy with a prime minister at the helm and ceremonial president as head of state, also shows some of the down sides to parliamentary democracies.

The ruling center right party of Prime Minister Pedro Passos Coelho win the most votes, yetit lost it’s majority. So now despite winning, his party has to form a coalition government with other parties. Portugal has seen coalition governments and they tend to be short lived. PM Coelho can form a coalition with left parties, who are against the spending cuts and tax hikes of his party.

If the prime minister fails to form a government, the president may ask the leftist parties, such as Antonio Costa’s Socialists to form a government. So get this, despite Coelho winning most of the votes, he may end up leaving office and his party NOT ruling!! The socialists may end up forming a government, with communists and Eurosceptic parties.

http://www.bloomberg.com/news/articles/2015-10-16/portugal-s-costa-seeks-stable-alternative-to-a-coelho-government

This is if the current PM fails to form a government, than the president may name someone else as prime minister.

Now in presidential systems once you win the election, you are the president unless you died or changed your mind, which in case someone from your party takes charge.
Regarding parliamentary democracies, some are often formed through coalition governments, while others win absolute majorities.
Turkey will hold another election a second time this year due to failure to form a government.

So parliamentary democracies are not immune to deadlock.

If not a particular party, then a coalition. My point was that whatever political group is in charge it has the clear power to act.

A pro of the parlimentarian system is that you cannot have a deadlock between house and president.

The con is that you do not have an independent review of the executive.

This is particularly a problem with UniCameral systems (only one house, instead of senate and reps), where the tendency is to become more corrupt and out of control than would otherwise be expected.

The con of bi-cameral systems is that you can have a deadlock between senate and reps. This might be a problem in situations where you don’t have a third party (Army, President, Queen) to sort things out: this was the traditional view of the Left in Australian politics, that the senate blocked reform, and that a unicameral presidental system was the solution.

In the other common view, it is particularly a problem because it gives the Army, President or Queen an opportunity to sort things out. This is a common view of the Left in Australian politics, partly because they’ve had control of the senate and used it to block things, so now it doesn’t seem like such a bad idea now.

The more interesting idea is that the Independent Execuative reduces the political legitimacy and moral responsability of both President and House(s). That it is an underlying cause of problems, rather than the direct cause. Interesting because at present it seems to be an un-answerable / un-arguable theory.

I think the point was that some countries don’t normally have majority parties. Israel, for example, has never had a party with a majority in the Knesset.

But if that is the point clairobscur was making, it’s not accurate. It’s not that the Prime Minister is the leader of the party that has a majority in the House; it’s that the Prime Minister is the leader of the party that has the confidence of the majority of the House.

There can be coalition governments, such as the recently concluded one in Britain, where PM Cameron’s Conservatives did not have a majority. There can also be minority governments, where the government does not have a majority, and does not form a coalition, such as the governments of Callaghan and Major (1996 onwards).

As well, Nava has posted (post 36) that in Spain the leaders of two regional governments were not the leaders of their parties. I’m curious how that worked?

That’s an odd definition of “winning” - if he lost seats and lost his majority, how do you conclude he “won”?

That’s a feature, not a bug. The person which can gain the confidence of a majority of the House gets to form the government. If the current Prime Minister no longer has the confidence of the House, and the leader of some other party does have the confidence of the House, then that other person should form the government.

Well his party got the most votes, so he is in first place whether or not it got the majority or not.

As for your second point, yes that the feature which seems strange in presidential republics.

I waited a while to respond because I wasn’t sure you were serious.

Pick a half dozen at random and let me know how many weren’t aimed at an elected president:

The example I think people would think of most is Egypt in 2013.

Of course, the coup plotters do tend to say that the elected president was dictatorial. If you have what amounts to an elected king, people will say that.