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Canadian and American politics compared

From Academic Kids

Though there are many similarities between the politics of Canada and the politics of the United States, there are also important differences. For example, at Canada's founding in 1867 the example of the disintegration of the United States during its recent civil war inspired the framers of the British North America Act to provide a highly centralized government for Canada; however, later Canadian and imperial events, described in this article, resulted in Canadian government becoming less centralized than American government.

Contents

Origin of differences

There are a number of explanations for why Canadian and American politics are different:

American Revolution approach

Some believe that the differences date to the American Revolution. This view was the dominant one in most of the studies of Canadian history. With the creation of the United States of America, the founders of that nation rejected the British monarchy and the Westminster system. In contrast Canada was created by the British Empire, and thus it chose to emulate the British Government. However, Canada copied some concepts from the US, such as a written constitution.

Likewise the origin of the differences between the political polices of Canada and the United States can be traced back to that original divide in 1776. The revolutionaries were motivated by an ideology stressing independence, innovation and the rejection of class systems. Canada, whose population included a large proportion of United Empire Loyalists (Americans who had left the United States so that they could remain under the British Crown) chose a more pragmatic, non-ideological path. George Woodcock has argued (in The Century that Made Us: Canada 1814–1914) that Americans are revolutionaries, dedicated to an ideology they believe makes their country the best in the world and a beacon of democracy, while Canadians are rebels who want chiefly to be left alone. The difference between the origins of the two nations is often said to be illustrated by the contrast between a key phrase in the American Declaration of Independence, "Life, Liberty, and the Pursuit of Happiness," and a key phrase in the Canadian 1867 constitution, "Peace, Order, and Good Government."

Fragment thesis

The fragment thesis, first advocated by Louis Hartz and later applied by others to Canada, argues that a nation's political culture is the product of the immigrants who formed that nation. Thus the American political tradition originates with those leaving Britain, either because of religious prosecution or to pursue trade and make money. Neither of these groups was keen on powerful government and they were much affected by the writings of British political philosophers John Locke and Thomas Hobbes. By comparison, some of those who founded English Canada were United Empire Loyalists who had lived in the United States but who wanted to remain under the British Crown. French Canada was formed by settlers loyal to an autocratic monarchy and the Catholic Church. Canada thus was originally far more conservative than the US. In later years, however, Canada was a major destination of Eastern European socialists and British Fabians that have given modern Canada a much stronger leftist bent than the United States. Many of the American draft dodgers who arrived during the Vietnam War may also have contributed to Canada's leftist political culture, although that contribution may well have consisted of replacing Canadian socialism's traditional class analysis with American identity politics.

Laurentian thesis

The Laurentian thesis ascribes the differences between Canada and the United States to a period much earlier than the revolution. It argues that the differences are based on differing trade patterns. While the US's trade in its early years ran almost entirely north-south along the eastern seaboard, Canadian trade patterns ran east-west along the St. Lawrence River. This thesis was advocated by Donald Creighton. This dependence on one river led to the domination of Canada by Ontario and Quebec and the peripheralization of the Maritimes and the West.

Religious thesis

The religious thesis ascribes the differences between Canadian and American political cultures to the differing religious make up of the countries. The United States for most of its history was overwhelmingly radical protestant, with most of its people belonging to churches that were evangelical and non-hierarchical. In Canada by contrast the Anglican Church dominated English Canada while the Catholic Church dominated in Quebec. Both of these churches were very hierarchical leading to Canada's long standing predisposition to deference towards authority. In recent decades however, Canadians have been seen as less deferential to authority then they had been in the past.

Staples thesis

The staples thesis, introduced by Harold Innis argues that Canada became a distinct entity based upon the exploitation of certain staples by the Europeans. New France and then Canada until about 1800 was completely dependent upon the fur trade for its existence. Since it was dependent upon exports to Europe no revolutionary zeal took hold there. Innis argues that the borders of the fur trade very closely reflect the borders of modern Canada. The fur trade was eventually superseded by the timber trade and the wheat trade but the close links with Europe remained.

'Court' or Statist thesis

This thesis developed by Michigan State University professor Gordon T. Stewart in his book The Origins of Canadian Politics : a Comparative Approach argues that the differences in Canada's political culture stem from developments which occurred between 1760 and 1848 in the Canadas - sharp partisan battles, intense use of patronage, strong one-man dominance in party leadership, and a 'statist' orientation. Responsible government in the central Canada came only after a "prolonged, violent and bitter struggle" unlike the maritime provinces or other British settler colonies. The struggle between Loyalist, British monarchical and French-Canadian values led to a unique political culture.

Division of powers

Both countries are federations. In Canada the sub-units are known as provinces and territories; in the United States they are known as states and territories (United States territories include the District of Columbia, Puerto Rico, and a few others). Canadian government is usually considered to be the more decentralized, although this assertion is disputed – as we shall see, Canada has found ways to institute national programs despite its decentralized government. Nevertheless, Canada is one of the only countries in the world where the combined budgets of the provinces or states exceed that of the federal government. Canadian provinces are responsible for most of Canada's social safety net, including health care, welfare, and education.

In the United States residuary or reserve power (those powers not enumerated in the constitution) is reserved to the states. Originally, Canadian residuary power was reserved to the federal government by the British North America Act, so that Canadian government was highly centralized. However, in 1896 the Judicial Committee of the Privy Council ruled that the federal government could exercise its residuary power only in time of war. This decision soon led to an increase in provincial power and responsibility.

The British North America Act had assigned property and civil rights to the provinces at a time when responsibility for these rights involved little more than regulating civil law. However, once the federal government lost its reserve power, new areas of government activity such as labour laws, pensions, and social insurance became the responsibility of the provinces, as regulators of civil rights, rather than of the federal government. Standards of social service soon varied widely from province to province.

In order to reduce these differences, national programs in fields of provincial jurisdiction, such as health care, have gradually been negotiated between the federal government and the provinces, and are co-ordinated by the federal government, which largely finances them through transfers to the provinces (chiefly the Canada Health and Social Transfer; territories receive an additional transfer to compensate for higher costs in the North). Provinces retain the option of raising their own taxes to pay part of these programs, although they may be unable to make use of this expedient for economic or other reasons. Provinces may also withdraw from these programs; Alberta has considered leaving the national health care program. Finally, provinces retain other powers in the areas covered by national programs.

The provinces have exclusive jurisdiction in many fields which are federal responsibilities in the United States. Primary and secondary education are the most prominent, each province's education system being unique, most noticeably in secondary education. Quebec is responsible for handling immigration into Quebec, and other provinces have the option of taking responsibility for immigration. Quebec also collects its own income tax (other provinces have their income taxes collected more or less as a surcharge on the federal income tax) and runs a pension plan parallel to the Canada Pension Plan; other provinces also have these options, and Ontario and Alberta have recently expressed interest in collecting their own income taxes.

In the United States the federal government exerts a great deal of power but because of the checks and balances in the US system this control is often tempered by the different branches. While in Canada the criminal code is federal legislation, US states have many differing laws, creating differences in everything from gun control measures to capital punishment. While each state has its own police force, unable by law to arrest in another state, several Canadian provinces contract with the federal police force, the Royal Canadian Mounted Police, to provide provincial police services.

The United States has a bicameral legislature. Each state has equal representation in the Senate, regardless of population, and representation based on its population in the House of Representatives. American state governments are like smaller copies of the federal government - only Nebraska has a unicameral legislature; the rest are bicameral. Originally, Canadian provinces had bicameral legislatures. Over time, however, they have eliminated their upper houses, and are now all unicameral. Many similarities remain, however. As governors are similar in role to the president, so Canadian premiers are comparable to the prime minister.

Municipal powers

Canadian municipalities have no rights whatsoever, legally, and are 'creatures of the province' in which they are located. They cannot sue nor can they apply moral purchasing standards in defiance of provincial standards. Provinces may even merge and divide cities at will, without consultation, and may ignore results of any referendum at the municipal level. For details of a current controversy, see either the Toronto, Ontario article, and a discussion of the 1998 amalgamation or Montreal, Quebec which was amalgamated in 2002 by the Quebec Government.

Optional provincial powers and Quebec

Canadian provinces may opt in or out of several national programs, especially those which are the results of federal-provincial negotiation. The province which has opted out of the most programs is Quebec. Quebec is primarily French-speaking and like Louisiana in the US, follows French civil law. Quebec's public pension and social insurance schemes are kept in separate funds from those of the rest of Canada, and are managed by the powerful Caisse de Dépôt fund, which often provides investment capital to Quebec-based businesses that are deemed strategic by its government. Quebec also regulates immigration to its territory, and has refused entry to people who had been accepted by the federal government for immigration to Canada. Other provinces have the option of instituting systems like Quebec's, and governments of both Ontario and Alberta have expressed interest in doing so.

The politics of Quebec tend to revolve around the question of Quebec independence from Canada, to create a new French-speaking, sovereign nation state, associated in an economic union with Canada inspired by the European Union. The large parties (Parti Québécois is independentist, the Liberal Party of Quebec is federalist) are opposed on the question, called in Quebec the National Question.

There is no state in the United States, by contrast, where state politics is so dominated by a party with the goal of separation from the USA. Puerto Rico, which is a non-state commonwealth within the United States, shares some parallels with the Quebec situation, as its population is primarily Spanish-speaking (as opposed to the English-speaking USA). Nevertheless, at the last plebiscite, Puerto Ricans voted to remain a commonwealth, with that option narrowly getting more votes than the option of becoming a state, and with the option of political independence coming in a distant third.

Equalization payments

All provinces contribute to an equalization fund which makes 'provincial equalization payments' to the poorer regions to ensure that comparable levels of service are provided throughout the country at comparable rates of taxation. Seven of the ten provinces currently receive such payments. British Columbia, Ontario and Alberta are the only provinces which do not.

The negotiations of provincial relief, and the draining of human capital (properly individual capital) from poorer provinces to richer ones, are constant concerns of Canadian provincial premiers. In the post-World-War-II period, Atlantic Canada lost many people to Central Canada (especially Ontario) and to Western Canada (to mostly Alberta in the 1970s and 80s oil boom, and to British Columbia later).

From time to time, Canadian premiers have made intolerant remarks about this situation in public. Alberta Premier Ralph Klein once famously offered any unemployed person "a free bus ticket to Vancouver" (to exploit that government's more generous assistance). Ontario Premier Mike Harris once famously referred to Atlantic Canada as "welfare bums". Both reflected underlying resentment of making payments to poorer regions, often voiced by constituents in the generally more politically conservative provinces, who feel they are paying for the social assistance in these other places.

Although these politics of 'have' and 'have-not' states are also present in the United States, there is less subsidy of the latter by the former, and more appreciation of the role 'have-not' states play in providing labor to 'have' states, and in serving in the military.

Political parties

There are four political parties with seats in the Canadian House of Commons. Both countries continue to use a first past the post system of electing representatives. This can sometimes work to exaggerate regional differences and interests, whether in the name of Quebec or of the southern "Dixiecrats".

The vote-splitting effect on the Canadian parliamentary system has often resulted in governments that have an absolute majority of representatives elected by far less than half of the overall popular vote, and effectively accountable to no one until the next election. In the United States, similar results can be produced by the presence of third parties or by the Electoral College. George W. Bush became president with fewer votes than his opponent, Al Gore, because he carried states with more Electoral College votes, while Bill Clinton became president with less than half the popular vote in 1992 and 1996 because of the presence of a strong third party. While it is difficult for third parties or independents to be represented in the United States at any level below the presidency (this usually requires an exceptional personal popularity, such as Jesse Ventura in Minnesota, or great wealth, such as that of Ross Perot), third parties have played important roles in many presidential elections. Since the Second World War alone, parties led by Strom Thurmond, George Wallace, and Ross Perot have obtained significant percentages of the popular vote for the presidency. Ralph Nader's candidacy in 2000 is considered by many Democrats to have elected George W. Bush even though most Americans opposed him.

The four Canadian political parties currently represented in the House of Commons are:

Three members of the former Progressive Conservative Party who did not join its merger on December 8, 2003 with the Canadian Alliance to form the Conservative Party of Canada continued to sit as self-described Progressive Conservatives, but were all defeated, or declined to run in the 2004 election.

The rise of the Bloc and decline of the Conservative party very drastically changed the political landscape of Canada. Before that, federal politics were dominated by two parties; the Conservatives and the Liberals.

Although the Clinton-era Democrats also moved to dominate the center of the political spectrum in the United States, they did not manage to successfully divide and conquer their opponents. Nonetheless the rise of the Reform Party of H. Ross Perot in 1992, and the rise of the Green Party of the United States in 2000, could both be said to have 'split the vote' and elected a candidate of opposite political views. Other third parties which played important roles in post-World War II presidential elections were Strom Thurmond's Dixiecrats and George Wallace's American Independent Party.

In the United States, by contrast, splits in the solidarity of 'the right' and 'the left' have generally been rather temporary, and quickly re-formed by binding together new coalitions, despite a more distinctive and enduring "liberal vs. conservative" culture that tends to make American political culture more dualistic. However, one of the most important changes in American politics over the last 40 years has been the switch in allegiance of many Southern white voters from the Democrats to the Republicans.

Bureaucracy

A key and often unnoted difference between Canada and the United States is the role of professional bureaucrats. In Canada, as in the UK, very few appointed officials lose their jobs during a shift of government even to a new party. While the Prime Minister of Canada has power within his government, these powers do not extend to the unionized public service.

In the United States, by contrast, over 2500 jobs are direct appointments of the President of the United States, cabinet ministers need not be drawn from elected Members of Congress/Parliament, and "the whole top rank of every federal department is swept away and replaced" with each election. This is very different from the UK public service and Canadian public service situation, and creates very different dynamics, most notably in the conduct of Ministers vs. Secretaries:

A British or Canadian Minister is often in his or her job for a short time, not a specialist in the particular area of government, and must trust his or her Deputy Minister to convey his or her requests to the bureaucracy underneath.

An American Cabinet Secretary always takes one job for the duration of the Administration, unless they are replaced or resign from the government entirely. They have great power to replace their assistants, which extends deep down into the agencies they control, which have no effective unions.

While there are plenty of globally-experienced Americans appointed by each President, they are of course different people, and tend not to be 'insiders' to international institutions, which engage in constant diplomatic and interest-group intrigue, requiring constant attention.

Centralization of power

In Canada there are far fewer "checks and balances" than in the United States. It may be argued that the Prime Minister within Canada has vastly more power than the American president does. Since Canada's legislative and executive branches are effectively fused, the Governor General (the Canadian representative of the head of state, Queen Elizabeth II) is a figurehead who does not exercise what few real powers the position has.

Unlike the US Congress, the Prime Minister will almost always have the largest group of supporters in the House of Commons. Also the Prime Minister's Office maintains strict party discipline over members of parliament of the party in power. This control has been tightened since 1968 as governments have consolidated power in the Prime Minister's Office.

In the United States there are often periods of cohabitation where Congress is controlled by a different party than the White House. The president also has very limited control over the members of congress and must often bargain and make deals for support there. On the other hand, the Prime Minister does not have the luxury of cohabitation. If a majority of the House of Commons votes against the government on a matter of confidence, the Prime Minister must resign or call an election. The Prime Minister of a minority government, therefore, is in a far more precarious position than any American president, whose term is guaranteed by law. The minority Clark government of 1979-80 is famous for having attempted to govern as if it held a majority in the House of Commons; it fell in nine months.

The membership of the federal judicial branch in Canada is also closely controlled by the Prime Minister, who has virtually complete power over the decision as to who becomes a Supreme Court judge. In the US, by contrast, all judicial appointments must be approved by the Senate. Until 1982, the Canadian judicial branch was far less powerful than the US one because Canada had nothing comparable to the US Bill of Rights. However, in 1982 under the urging of then-Prime Minister Pierre Trudeau, the Canadian Charter of Rights and Freedoms was added to the constitution giving the courts far more power. However, in Canada's charter there is a notwithstanding Clause, which allows any government to protect a bill from certain areas of the charter for a period of five years. The Supreme Court has also ruled that the Charter does not apply to the civil law.

The centralization of power in Canada has certain benefits and certain liabilities when compared with the American system. A clear line of authority means it is very clear who in government is responsible for any given issue. Unlike in the US, the Prime Minister is wholly accountable for the economy, security and other national concerns. The rigid control of Members of Parliament in Canada also serves to reduce corruption and reduce the influence of money in Canadian politics. Unlike American Senators and even Representatives, MPs do not need to raise great deals of money (one of the reasons why is described in the next section), and because they are far less powerful there is far less interest from companies to donate to them. The advantages of the US system include that it is more flexible and more representative as each congressperson can make their own decisions on each issue. This leads to greater regional representation by each party and helps discourage the proliferation of third parties which occurs often in Canada, although one may reasonably question whether the absence of third parties is on the whole an advantage.

Size of constituencies and campaign financing

The approximately 31 million Canadians are represented by 308 elected federal members of Parliament, or about 1 for every 100,000 Canadians of all ages. The number of seats in Parliament is readjusted every ten years, based on the results of the most recent census.

In contrast, the approximately 280 million citizens of the United States are represented by 535 elected federal legislators (435 members of the House of Representatives and 100 senators), or about 1 for every 500,000 Americans of all ages, and seats in the House of Representatives are apportioned so that the total always remains at 435 (except possibly in extraordinary circumstances – the last time the number increased temporarily was to give Alaska and Hawaii representation in the House following statehood).

Furthermore, American candidates for senator must campaign over an entire state, while candidates for president must campaign across the entire country. In Canada, however, each member of Parliament represents a local riding, the vast majority of which are quite small (only in the far north does sparseness of population create large ridings). Urban ridings in Canada sometimes cover only two to three square miles (5 to 8 km²). As well, Canadians do not directly vote for Prime Minister, but only for their local candidate, although in practice the party leaders do have to campaign nationally on behalf of their parties.

The effects of this difference on federal political financing are enormous. American candidates, campaigning over larger areas to a larger population, require much more money than Canadian candidates, and indeed more than candidates in any other industrialized democracy.

Canada, starting with the federal election of 2004, has strictly limited political donations by corporations and unions; in particular, corporations and unions may not make donations to registered political parties or to candidates for the leadership of a party, and their maximum contribution to a candidate for member of parliament is limited to $1,000. In addition, the political campaigns of all parties which obtain certain percentages of the vote receive public campaign funding, so the influence of corporate and union money is further diminished. In previous elections the influence of corporate and union donations was still less than in American elections, because of the much smaller cost of campaigning.

In the United States, however, campaign contributions remain paramount, and the potential for influence by large campaign contributors is much greater. The American political dynasty – a family which has either used its wealth to produce generations of influential politicians or become wealthy through politics and produced generations of influential politicians – has no real equivalent in Canada, since great wealth offers fewer electoral advantages (Belinda Stronach's campaign for the Conservative leadership is an example of how ineffective great wealth is in Canadian politics, although going from political neophyte to second place in a major leadership race and shadow-cabinet prominence could be considered an achievement in itself). One possible exception to this generalization, though, is the current prime minister, Paul Martin, a wealthy industrialist and the son of a federal cabinet minister. His own sons, however, have stayed out of politics.

As a result of these difference Canadians are also able to deal more directly with their elected federal representatives. All members of Parliament maintain constituency offices, and most Canadian city dwellers are only a few minutes away from their member's office.

Multilateralism

Canada is committed to the concept of multilateralism and collective security. It is one of the strongest backers of the United Nations and supports most international initiatives, such as the Kyoto Protocols, the International Criminal Court, and the International Ban on Land Mines. The United States pursues both unilateral and multilateral policies at different times, depending on self-interest. Many Americans have problems with the United Nations and are unwilling to see their country's sovereignty impinged on by international organizations. Both Canada and the United States are committed to international economic organizations such as the International Monetary Fund, the World Trade Organization and the World Bank.

Summary

To summarize the differences:

  • Canada:
    • Hybrid liberalism civic nature with a strong strand of Tory (conservative) deference.
    • Regional distinction and high decentralization
    • Multiparty system.
    • Relatively inexpensive election campaigns
    • Post-materialism of 1960s.
    • Oppositional relationship generally except for business links with parties and elites.
    • Effectively fused executive and legislative branches
    • Very powerful Prime Minister when the government has a majority, very weak when it holds a minority of seats in the House of Commons
  • United States:
    • Constitutionalism
    • Acceptance of limited state
    • Checks and balances
    • Individualism
    • Civic Culture
    • 2 Party System made up of catch-all parties.
    • Expensive election campaigns
    • Post-materialism and protest in the 1960s

See also

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