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More similar than the other major Western democracies at least, agreed. Legolas Send a noteboard - 08/03/2012 09:32:55 PM
Specifically, what you said about the French presidency being a far more powerful position if his party also has a parliamentary majority. The US president is in a similar, if not identical, position (hence Obama screwed the pooch in not taking advantage of the Democratic House and Senate majorities while he still had them.)

Indeed. Still, there's a big difference in the sense that the US president can always appoint his own cabinet, regardless of his party's position in Congress. A French president can indeed appoint a PM pretty much at will if his party controls the parliament, and has at least a strong voice in who will get which ministry, but if his party doesn't control the parliament, whoever does (or can create a coalition that does) can become PM and the president's say in the division of the ministries becomes essentially non-existent. At that point the president is left with little concrete power, and reduced to much the same position as the kings and queens of constitutional monarchies, or the president of e.g. Germany. He has a bit more power than those - I believe he still has the nuclear access codes, and might even have a veto of some sort - but not much more.

I suppose it must be possible for a president with a majority to annoy his own party so much that they decide to stop following his lead, vote in their own PM and bring him into much the same position, but I don't believe that has happened yet...


It is more a matter of the PM being both a member of the legislative majority AND head of state. In some ways that gives Britains PM greater (if more precarious) power than the US president. The PMs situation seems more like Obamas before 2010 or Clintons before 1994; he may need the Whip to keep a few unruly party members in line, but seldom faces an openly hostile majority (if only because such majorities tend to relieve him of that burden, by bringing down his government. :P)

Very true. Minority governments can happen, but they tend not to last very long as it only takes one lost vote of non-confidence to put an end to things. Yet another difference with the US, that... a PM can be dismissed by a simple vote of non-confidence in the House, at any time, if a majority can be found for it.
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