Would Like a 'Parliamentary Political Systems for Americans' Primer

I have found that this is what often trips up Americans. With fairness to our American friends, they often think that the Queen rules, approving some laws that she likes, and disapproving others that she does not. They tend to give her more powers than she really has. In fact, she is constrained by her realms’ constitutions to the point where if she tried going against constitutional norms in any Commonwealth country, she’d be tossed in a moment.

It’s been said before that the Queen reigns, but does not rule, and thus, she cannot act politically. I am reminded of the line (paraphrased) in the 1991 movie King Ralph, where King Ralph is reminded that he cannot act in political crises. “But that does not prevent you from creating them,” says his private secretary. Thankfully, King Ralph, while surprised that he cannot, does not, and the ship of state sails on.

Which is correct, except for the implication that as Monarch he could create more than one crisis.

I think you left out a “not” in there.

Doh! Obliged!

To the extent that there can be a cut-out between HM and PM, through their officials, so that HM is allowed to sail above it all, while her officials tell the PM’s officials that they think HM might want to be re-assured that the PM has considered this or that angle, etc., etc., in the hope that the PM wll take the hint: I read in one of Peter Hennessy’s books of an incident during the Rhodesia crisis of the early 60s. Harold Wilson wanted to suggest that the Queen should do a tour there (in the hope that this alone would bring the white settlers, as loyal to the old ideas of empire and monarchy, to their senses), and Palace officials (realising that this would mean heavily involving her in controversy, to put it mildly) wrote to the PM’s private office to say that of course she would do whatever the PM advised (with a capital A), as long as the Advice came in writing and in specific detail - or in other words to ensure that he got the blame if it all went pear-shaped. And nothing more was heard of that idea.

We’re not routinely told what’s said when the PM has their weekly meeting with HM, but my guess is that on anything potentially contentious at most she’ll say, “Are you sure that’s quite wise?”

But that’s not necessarily definitive of all parliamentary systems: in a republic with a similarly largely ceremonial President (such as Ireland or Germany), the Head of State might be much less ringfenced away from controversial issues, though perhaps not necessarily currently specific legislative debates

Those are all good points. Just to highlight - all my comments above are about the “Westminster system” , that is, the parliamentary system originated by the British Parliament, sitting at Westminster, and inherited by countries like Canada and Australia.

The European countries also have parliamentary systems, but they have grown out of their own constitutional traditions and have some differences from the Westminster model. I don’t know enough about them to comment.

For Americans trying to figure out parliamentary systems, probably the easiest explanation would be, “Imagine if the House of Representatives were the most powerful part of the government.”

Members of the House are directly elected by voters in their district, and then vote for who will be Speaker, usually along party lines. So everyone who’s voting Democrat knows that they are, in effect, voting for Pelosi as Speaker, making her the highest elected official in the country, with a lot of the powers that currently vest in the President. This would be the equivalent of the Prime Minister.

It’s not a perfect analogy, but it may help.

That analogy only goes so far. Yes, voters in 2020 knew that Pelosi would definitely be a strong contender for Speaker, but she could have faced a challenge for the position from other Democratic members of the House.

In the parliamentary system, the party leader is chosen prior to the election (usually some years prior), so if that party wins, the leader will be PM. It would be highly unlikely for a leader who just lead their party to government to face a challenge.

Government Business - Legislation

The usual passage of a Bill through the Australian Federal Parliament is this flowchart provided by the Parliamentary Education Office. I think it would be reasonably standard in the Westminister system.

One of the features of a Bill under the Westminister system is the Long Title.
The ‘long title’ is the bill’s full title and provides the purpose or scope of the bill, for example ‘A bill for an Act to repeal certain obsolete Acts relating to agriculture, and for related purposes’. Each bill also has a short title—say “Agriculture Legislation Repeal Bill 2019”.

Under Parliamentary Standing Orders any and all proposed amendments to the bill which are deemed as outside the purpose and scope of the bill are rejected. As a consequence the legislative devices of adding riders and earmarks, which seem to be SOP in the US, are not seen in Westminister systems.

Just a quick primer on the Norwegian system and how it differ from the British:

Parliament is elected for four years, there is no option for calling an election outside of that.

Members of parliament are elected on a county* basis. The smallest county currently has 4 representatives, though one of those is an equalizing mandate. (There’s a total of 150 representatives allotted the 20 counties, but 19 additional representatives are distributed to improve national proportional party representation). Candidates closest to being elected in a county serve as designated alternates in case of temporary or permanent absences.

The government is formed by the party, or parties, who can build majority support in parliament, that has been de facto law since 1884, but wasn’t technically de jure until constitutional changes in 2007. Even after the 2007 update the constitution still reflects the pre-1884 reality where the Monarch created the government based on his personal desires and a lot of the nitty gritty is based on custom or flows from the reality of the party system rather than written law.

Though the prime minister is customary the leader of the largest party in the parliament/coalition, ministers (including the PM) do not have to be members of parliament, or even members of the parties, though, especially in a coalition government, they will be. While ministers they will be replaced in parliament by the designated alternates.

A government that loses support in parliament can be ousted through a vote of no-confidence, but this usually leads to either a very weakly supported coalition or even a minority government coalition since they will require the support of the same members of parliament. Changing parties while in parliament is exceptionally rare.

*The historical counties recently stopped being an administrative unit in a (still) controversial reform.

Another very important point of difference. Also, at Westminster (and I assume also in similar systems), the scope for any ordinary member other than the relevant minister(s) to initiate legislation is very constrained (and AFAIK cannot mandate a spending commitment). There’s a procedure to lodge a sort of Bill which might allow for the idea to be debated, but not proceeded with unless the Government takes it on board as one of their proposals and finds time for it to be taken seriously; and there’s an annual ballot for a limited number of “private member’s bills” where a back-bencher who comes high in the ballot has a serious chance of getting some legislation through (but might still need a fair wind from the Government) - this latter has sometimes been used as a way for ministers to interest a ballot winner in a proposal ministers haven’t been able to get time for, or which the ministers might feel too hot a potato to become a government proposal (e.g., the 1960s reforms on the laws on homosexualilty and abortion - the sort of topic usually not taken as party issues, but rather as “conscience” issues with a free vote).But the bulk of business follows the government’s agenda, with some guaranteed time for the Opposition parties to raise their choice of issues (but they can’t bring forward competing legislative proposals either - at best, amendments at committee stage).

Of course, it is possible for a government party MP to try to make life awkward for ministers in various ways in order to get some sort of benefit for their constituency or a pet cause, but their effectiveness at that varies with the size of the government majority and the degree to which they in turn might have life made awkward for them by the government whips.

One major difference in the Norwegian system from the American is that a lot of the votes are not over laws. The national budget for instance is not a law, though it is voted on by the parliament.

Also the preparatory work for new laws is done by the bureaucracy and then debated and amended in parliament. Tacking a bunch of tangential or outright irrelevant decisions onto a law doesn’t happen, though I don’t know if it’s just differences in custom or if there are rules in place restricting it.

What are some of the worst failures? E.g., Israel is now holding its fifth(?) election in two years, which seems pretty unstable, but surely it’s not even that bad compared to some other countries and time periods.

I think explaining the nuts and bolts of who is on the ballot would be helpful. Let’s take the UK as an example. I’m under the impression that in the UK that people vote for a party, with ballots listing Labour, Conservative, etc. rather than a particular candidate. Is that correct? If so, how do the parties determine who will fill the seats that they won? Let’s say that Party X wins 100 seats in parliament. Does Party X have a list of people who will become MPs, ranked from 1 on down, and whoever is number 101 on the list is out of luck? Is there a separate primary, and if so who determines who gets to vote in those primaries?

In terms of the Queen taking a very detached and, at most, very light-handed approach with respect to involvement in politics, I’m reminded of the time that the former head of the Green Party in Canada wrote to the Queen complaining about alleged election irregularities and asking the Queen to start a Royal Inquiry into the allegations. She received a reply explaining with exquisite politeness that the Queen doesn’t do that sort of thing, and that she (the party leader) seemed not to grasp how a constitutional monarchy works. It seems that she (the party leader) expected the Queen to get on the phone with the Prime Minister and indignantly declare, “don’t make me come over there!”

https://nationalpost.com/opinion/kelly-mcparland-elizabeth-may-gets-civics-lesson-from-the-queen-in-appeal-for-intervention

While this thread is on parliamentary systems–it would still be best if we get factual claims about the American system correct. The President can only fill cabinet positions with the advice and consent of the Senate, and this is frequently a major limitation to whom he can appoint and get confirmed to these positions. An unfriendly Senate can torpedo a President’s desired secretary, and Congress can also pass laws limiting who is allowed to serve as a secretary–for example there is a law that says no one who was an active duty member of the military in the last 3 years can be appointed as Secretary of Defense–that rule was broken for both James Mattis and current SecDef Lloyd Austin, but they had to approve a statutory waiver both times in Congress.

I’ve never met an American that was under the impression that QEII takes any active role in government.

The parties decide who gets to appear on the ballot for their party in a given constituency, but British ballots show the local candidates by name and the party they are affiliated with–they do not simply vote a ballot that only has a party preference and no individual candidate.

This page has an example of a typical British paper ballot:

Ballot papers and pencil at polling booth in Newington, South… News Photo - Getty Images

The selection of candidates for a constituency are up to the processes of the parties, historically the Conservatives and Labour had slightly different processes, although they are more similar now.

Prior to 2001, both parties maintained a “party list” of acceptable candidates for office. These would be members of the party in good standing, who typically had built connections and friends, and who had spoken well at selection meetings. However, the final decision came down to different processes.

For the Conservatives, the local Constituency Associations largely controlled who would ultimately be selected as a candidate. For Labour, Ward and Trade Union affiliates could add names to the official party list, and the Constituency General Committee made final decisions.

From the early 2000s forward more experimentation occurred with selection of candidates, and now all parties follow a process roughly similar to this:

  • Party members in good standing can apply to become candidates, there is usually a required membership duration before being eligible (varies by party)
  • There is a round of assessments and interviews with interested persons. These include written assessments of things like writing skill.
  • From this, the parties prepare approved lists of candidates
  • Party members can then participate in selecting the candidate who will be on the ballot

Note that in the United Kingdom party membership is not at all like being a “Democrat” or a “Republican”, which generally just implies ticking a box when you register to vote. In the UK to be a member of a political party you have to formally file paperwork and apply to join a party and pay a fee for joining, the number of people in the UK who are actual party members as opposed to party supporters is hugely different. The two largest parties have millions of supporters, but only a few hundred thousand members.

Something worth noting is this newer process has exposed British candidate selection to more influence from non-party leadership. One of the reasons that Jeremy Corbyn was for a time able to get control of Labour is because he built a political movement called “Momentum” that registered lots of new people as Labour party members, and they voted pro-Corbyn in party votes, which dramatically eroded the power base of non-Corbyn Labour leadership. Corbyn’s power collapsed after he led Labour to a disastrous loss in a general election, which is also fairly normal in British politics, electoral losers rarely get second chances and are usually dumped pretty quick from leadership (there are some famous exceptions.)

The MP in question makes for a a good example. That article mentions that May is the only Green Party MP in the Canadian Parliament. Did she appear on the ballot in a district with a particularly high concentration of Green Party voters? If not, did she win her seat because nationwide 1% of voters (or whatever the threshold is) marked their ballot as Green Party? If the latter, how does the Green Party determine who gets to fill the seats that they win?

Nope. Or… not quite, the decision is made by the party before the election, so the voters vote for a specific person who’s from one party or the other.

Canada uses First Past the Post Single Member Districts–the same way that American House seats are filled. There is no mass voting for a party and then seat apportioning based on proportional representation. Canadians vote in single member district, and under FPTP rules the candidate who secures the most votes becomes MP for that constituency.

This means that whatever constituency May won election in, simply more people voted for her than anyone else.

It’s probably worth making very clear:

The system of deciding “how do we count votes in order to determine who has won a constituency election” is independent from whether or not a system is parliamentary. I think most (excepting Australia?) Westminster Parliamentary systems use First Past the Post–which is also called plurality selection. This means that many candidates run, and the candidate with the highest vote share wins–even if it is not a majority. I believe most (maybe all?) Westminster style parliaments also use “single member districts” (although I think Australia’s upper house uses a multi-member district), this means that the legislature is divided into x number of constituencies, each which represent a specific geographic area, and that area has one elected official to represent them.

Proportional representation is when voters vote for say, a preferred party, and then a number of seats are apportioned out to each party based on their vote share. In theory either the United States or the United Kingdom could adopt this instead of FPTP / Single Member, and still be a “Parliamentary” and a “Presidential” system, respectively.

What makes a system Parliamentary is generally this core concept: the Head of Government is the person who commands the majority faction in the legislature. A Presidential system the President is a separate office from the legislature and is elected through a separate process entirely unrelated to legislature.

There is nothing inherently stopping a Presidential system from using proportional representation, Instant Runoff Voting, plural districts etc. There is also nothing stopping a Parliamentary system from using those as well–in fact Australia does use IRV.