Comparative Political Institutions: Where Does Power Lie in Each Country?

• Pages: 67-108

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Comparative Political Institutions:

Where Does Power Lie in Each

Country?

Introduction

Did you ever wonder — who has more power, a prime minister or a

president? What is the dierence between Parliament and Congress?

How much inf‌luence does each country’s Supreme Court have, and

how does the judiciary inf‌luence democratic decision-making?

Returning to the theme of similarities and dierences, we note

how the core political institutions of both countries — the exec-

utive, legislative, and judicial branches — are strikingly similar,

yet equally strikingly dierent. Power may in fact be vested in the

people in both countries, but distinctive institutions bring that

abstract concept to life in dierent ways. is chapter outlines and

explains those dierences by comparing political institutions while

keeping in sight the core similarity that def‌ines the political systems

of Canada and the United States — democracy.

A. Comparing Democracies: Executive and

Legislative Institutions

Canada and the United States are both representative democra-

cies and share certain characteristics as such. ey both observe

THE SAME, ONLY DIFFERENT

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the rule of law (no one is above the law, not even the makers

of the law); they constitutionally guarantee certain rights and

freedoms (in a Charter of Rights of Freedoms in Canada and

a Bill of Rights in the United States); and power is vested in

the people in both countries and exercised by their freely chosen

representatives.

1) Checks and Balances Versus Fusion of Powers

In the United States, a system of checks and balances ensures that

power is divided between the legislative branch (Congress, made up

of the Senate and House of Representatives), the executive branch

(the President and Cabinet), and the judicial branch (the Supreme

Court and all the courts below it). e founders felt that “ambition

must be made to counteract ambition,” as James Madison wrote

in the Federalist Papers, in order to avoid hasty decision making

or abuses of power. e United States Constitution even forbids

members of Congress from holding oce in the executive branch

of the federal government.

In Canada, power is much more centralized, with the execu-

tive branch (the prime minister and Cabinet) being the key deci-

sion-makers in the system, giving orders and directives to the

legislative branch (the Parliament, made up of the appointed Sen-

ate and elected House of Commons). But note that the system of

checks and balances does not apply in Canada. Instead of an Amer-

ican-style separation of power, there is a fusion of power, as the executive

and legislature sit together in Canada in Parliament. Indeed, the

executive branch has to be chosen from among the members of the

legislative branch. at is why the Canadian prime minister and

Cabinet must be Members of Parliament (MPs), and is the central

feature of responsible government, the history of which we brief‌ly

traced in Chapter .

In Canada, we could say that the executive and legislative

branches work together more eciently than in the American sys-

tem. However, the price for eciency is a concentration of power

Comparative Political Institutions

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in the hands of the executive, as the prime minister appears to have

almost unchecked power to direct the government. is is largely

a function of something called party discipline in which all the

members of a given party take direction from their leader and vote

together as a bloc. is is necessary because the prime minister needs

the support of a majority of the MPs to pass legislation. In return,

the executive branch must be accountable to the legislative branch,

and explain its actions. us the prime minister and Cabinet stand

up in the House of Commons during Question Period and answer

for their policies. is is the core of the system of responsible gov-

ernment. e executive is responsible to the legislative branch, and

ultimately through it, to the citizens.

In contrast, in the United States, the president is constitu-

tionally prohibited from being a member of Congress. ere is no

system of responsible government in the Canadian sense of the

term. e president does not appear in Congress as the leader of

the party with the most seats and command Congress to do his

bidding. ere is no system of party discipline — although there

is deep partisanship that dierentiates Democrats and Repub-

licans. But there is no prohibition in Congress from members

“crossing the f‌loor” to vote with the other party, as there is in

the Canadian Parliament. ere is a need to negotiate and bar-

gain about policy decisions in the American system between the

executive and legislative branches. In the United States, when

apportioning blame for policies that are not working, a pres ident

will often blame Congress, leaders of Congress will blame the

president, and the voting public, which is to blame for electing

those people, gets frustrated.

It can be said that in the United States Congress, more than 

percent of proposed bills never get passed, but members of Con-

gress can and do have the opportunity to represent their constitu-

ents’ interests very closely because they have much more freedom

of action and independence than MPs in Canada. In Canada, 

percent of government bills do get passed, but constituent interests

are often sacrif‌iced due to party discipline.