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Comparative Politics (Lecture notes). Professor Sujian Guo Department of Political Science San Francisco State University. Comparative Political Institutions.

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Comparative politics lecture notes

Comparative Politics(Lecture notes)

Professor Sujian Guo

Department of Political Science

San Francisco State University

Comparative political institutions
Comparative Political Institutions

  • What is the political institution? A political institution is a structure with established and important functions to perform, well-defined roles for carrying out those functions, and a clear set of rules for governing the relationships between the people who occupy those roles. (An organization is a group of individuals working together to undertake actions and achieve certain goals. A system is a structure all of whose parts are interrelated with one another, having behavioral regularities and identity over time.)

For example
For example:

U.S. Executive

Foreign policy making Civil services

Presidency Bureaucracy

George W. Bush A group of individuals/officials/offices

Where are the political institutions
Where are the political institutions?

Political Institutions (legislatures, executives, and judiciaries)

Demand Decisions

Input Output

Support Policies/rules/


Environment (culture, religions, ethnics, and international factors, etc.)

The b asic structures of government
The Basic Structures of Government

  • Unitary systems: unitary systems have the concentration of power in the central government and the central government has a significant control over local authorities. A unitary government usually touches people’s daily lives in more ways than a federal government would. Ex. In France, elementary school curricula are drawn up by the central ministry of education in Paris in order to reduce regional differences.

  • Federal systems: federal systems have the decentralization of power while at the same time allowing the federal government enough power to run the country. The key of a federal system is that, first, local governments have a considerable degree of autonomy and authority in policy making and their powers cannot be easily overridden by the federal governments, and second, local governments have equal representation at the national legislative level.

The b asic structures of government1
The Basic Structures of Government

  • Legislature: the main purposes and functions of legislative bodies are to formulate the laws or make the rules that govern society. Legislatures initiate laws, propose constitutional amendments, ratify treaties, control tax revenues, and act as a check on the other branches of government.

  • Executive: the main purpose or function of executive bodies is the execution and enforcement of the laws enacted by the legislature. Executive bodies also make and execute public policy decisions, perform administrative leadership, and provide civil services, regulations, and “housekeeping.” Executive bodies play a variety of governmental roles in running the country on the daily basis, because the executive branch of government consists of the head of government and the head of state, the cabinet, and the bureaucracy.

  • Judiciary: the main purpose of judicial bodies is to handle day-to-day administration of the law, determine and clarify the meaning of laws and rules, mandate penalties for violations of laws, review the constitutionality of legislative enactments, ensure that the terms of the Constitution is not violated, and act as a check on the other branches of government.

  • Constitution: can be defined as the body of fundamental laws, customs, and conventions that define the composition and powers of political institutions and that regulate the relations of the various political institutions to one another and to the private citizens.

The united states vs great britain two models compared
The United States vs. Great Britain:Two Models Compared

  • Constitution: US constitution is “documentary,” and basic principles and relationships of three powers are clearly defined and regulated in written for them to follow. UK constitution is “non-documentary,” with a collection of custom, tradition, rules of parliamentary performance, and nothing in written to regulate the power structure and the ruling principle.

  • Parliamentary, executive, and judicial relationships: US political system is based upon separation of powers which have checks and balances on each other, whereas UK political system is based on the fusion of powers, the head of executive power is the leader of the majority party in the parliamentary, and carries out the policy of the majority party.

The united states vs great britain two models compared1
The United States vs. Great Britain: Two Models Compared

3. Power structure: US is federal system, the state power protected by the constitution, and the states are more autonomous, whereas UK is unitary system, local governments and their policies are controlled by the central government and can be modified by the central government on the nationwide base.

The united states vs great britain two models compared2
The United States vs. Great Britain:Two Models Compared

4. Executive leadership: (1) UK executive cabinet is responsible to the parliament, in contrast to US President’s cabinet which is responsible to the President himself. It is the UK cabinet to make policy decision, whereas in contrast in US it is the president to make policy decision; (2) UK bureaucracies are easier to dominate the policy-making in contrast to their counterparts in US, since the UK cabinet offices and civil services play a more significant role in policy making than their counterparts in US; (3) UK government’s legislative proposals or bills would be almost enacted into laws and the government can get what it wants since the prime minister is the leader of the majority party, with a highly party discipline, whereas US government’s legislative proposals or bills would face great challenges by the congress since the president is not the representative of any party policy, and no party discipline constrain the political behavior of party members in the parliamentary; (4) UK parliament has very weak check on the executive, whereas US congress has a real check on the executive.

The united states vs great britain two models compared3
The United States vs. Great Britain:Two Models Compared

5. How to get power. UK prime minister is elected by the majority party in the parliamentary, in contrast to US president who is popularly elected.

6. UK parliament has upper house and low house, and the upper house is composed of peers who serve British crown, which has nominal power in decision-making, whereas US has senate and congress, both of which has effective power in decision-making.

France a hybrid model
France: a Hybrid Model

1. A mix of US presidential and UK parliamentary systems, with head of the state and head of the government in two persons. French president is more concerned with foreign policy, appoints prime minister, while prime minister is more concerned with domestic affairs, and picks the members of cabinet and controls the bureaucracy.

France a hybrid model1
France: a Hybrid Model

2. Strong president and weak parliament. French president has great power at his disposal that no US presidents ever have. French president is 7-year term, but with no limit on terms; president is endorsed with an emergency power that allows him to rule by decree for 6 months; president can dissolve the parliament; president appoints prime minister and have a say in the composition of the cabinet. French parliament is relatively weaker than its counterpart in US, because the role of the French parliament has been reduced significantly in the 5th Republic as legislations are narrowed down and the power of parliament in spending or raising money is weaker than the 4th Republic. The parliament often does little more than establish “general principles” and leave them to the government to fill in the details by decree. The parliamentary standing committees are narrowed down to only 6, and work within limited period of time and are forbidden to produce “counter-bills” to government bills.

France a hybrid model2
France: a Hybrid Model

3. Power structure. France is a traditionally centralized government with a unitary system. National government is divided in 94 departments, below which there are thousands of communes, whose responsibilities can be defined and modified at the will of the national government. Decision making power is highly centralized. Bureaucracies play a much more significant role than US and UK, and are recruited from upper classes and well trained, provided by a large number of institutions specialized in training experts and specialists for government offices and civil services. They have a reputation of more efficiency.

France a hybrid model3
France: a Hybrid Model

4. France has multiple-party system similar to UK but different from US. However, French political parties have different families at left/center/right wings, emphasizing the interests of particular classes, which often lead to no single dominant party and more government turnovers. Parties are both ideological driven and issue-specific oriented; issues are more debated. France has a long ideological tradition and is more oriented to ideologies in elections, while Americans tend not define political parties in terms of ideology and not to vote in terms of particular ideological orientation.


1. Basic law is the name of German postwar new constitution, which creates a political arrangement to prevent those anti-democratic political parties from coming into politics, prevent centralization of government, protect political and civil rights, forbidden the discrimination of all kinds. German law is a codified law, based on Roman law.

2. Legislative: lower house, “Bundestag,” is popularly elected, and has the power to dismiss the head of executive, “chancellor,” while upper house, “Bundesrat,” is not popularly elected but composed of the heads of the state governments, “Lnder” (political/geographical districts), which represent the interests of the states in the national policymaking process, but not in the partisan political ground.


3. Executive: a divided executive, with head of the state and head of the government in two different persons, but it is closer to UK than to France, since the president, like British Queen, is largely ceremonial, and serves a symbolic function. The chancellor, similar to UK prime minister, is the chief executive responsible for government policies and responsible to the parliament, and the leader of the majority party in the lower house of parliament. If no one party enjoys an absolute majority, a coalition government will be formed and choose the chancellor. The chancellor can be dismissed by parliamentary vote of “no confidence.”

4. Parliamentary system is a combination of two electoral systems – a proportional system and a plurality system – one half of the parliamentary delegates are chosen on the proportional basis while the other half are elected on the plurality basis. The voters have two ballots – one for a district candidate, and the other for a party.


5. Power structure: Germany is a federal system, composed of 16 states, “Lnder,” which serve as a permanent check on the power of the center. However, German federalism has a number of unified features that make the states more powerful than American states and make the policy implementation function remarkably well. (i) state governments have their extensive inputs into the national-level legislative process their membership in the Bundesrat; (ii) the laws and rules of procedure for state governments are unified and standardized, unlike American federalism; (iii) differences between resources and expenditures in different states are made up by the system of tax redistribution or revenue sharing, and the states receive a large proportion of taxes.


1. The 1993 constitution outlines a presidential system of government, with a dual executive, with the head of state and the head of government in two different persons. It is more similar to France in many respects, such as strong president, weak parliament, and multiparty system, but the president has far greater powers than his French counterparts. The president is the head of state and commander-in-chief, and has the power to issue edicts, declare war, declare a state of emergency, schedule elections to the lower house of the Assembly, State Duma, and call a referendum. The president appoints the prime minister (which must be approved by the lower house; if three appointments are rejected, the president can dissolve the lower house and call for a new election), also appoints deputies and ministers (who are responsible to the president, not to the prime minister), the chairman of the central bank, the prosecutor-general, and all high-court judges.


2. The president powers are great, but not without limit. For example, the Federal Assembly, the upper house, can impeach the president, but only for treason or a serious crime. The State Duma, the lower house, can pass a vote of no confidence in the government, but the president can reject the vote. If it is passed again within three months, the president must either dismiss the prime minister or dissolve the lower house and call for a new election. The president cannot dissolve the house if it is considering impeachment, during a state of national emergency, or within a year of a vote of no confidence.


3. The legislature. A Federation Council (upper house), with 178 members, two from each of the 89 regions and republics of Russia, has jurisdiction over relations between the federal government and the republics, can examine all laws passed by the State Duma, and can reject any laws involving economic and defense issues. A State Duma (lower house), with 450 members, half elected by proportional representation in which each party puts forward a list of candidates and receives seats proportional to the number of votes it wins and half on a winner-take-all system from single-member districts.


4. Power Structure. Russia is a federal system. Russian federal system is more similar to Germany than to U.S., but the federal government has more powers than its German counterpart, in the sense that the Constitution allows the federal government to appoint leaders, delegate authority, or interfere in local politics if deemed necessary.

5. Russia has multiple-party system similar to France and Italy. Russian political parties have different families at left/center/right wings or pro-reformist (Russia’s choice, Yabloko, Women of Russia, Russian Unity and Accord, and the Social Democratic Party), centrist/reformist (Civil Union), and anti-reformist (Liberal Democratic Party, a neo-fascist party or right-wing nationalist movements, the Communist Party, and the Agrarian Party). Parties are both ideological driven and issue-specific oriented, and issues are more debated than their U.S. counterparts.


1. The 1947 Japanese constitution was imposed by the United States and its Occupation Authority after its victory in WWII. The constitution seeks to construct a system of representative democracy, with the emperor remains the head of state, but merely as a ceremonial figure. The constitution guarantees the fundamental rights of citizens and also pledges that “land, sea, and air forces, as well as other war potential, will never be maintained,” but this provision has not prevented the government from building “self-defense forces,” which was actually allowed to expand during the Cold-War U.S. and Soviet confrontation.


2. The legislature: Japan is a parliamentary system in contrast to the US presidential system. The Japanese parliament is the Diet, which consists of two Houses––the House of Representative and the House of Councillors. The primary power in the Diet rests with the lower house. Although the Diet is bicameral (a bill becomes law only when it is passed by both chambers), the lower house has the power to override, by a two-thirds vote for a second time, any attempt by the upper house to negate actions of the lower house. Moreover, the lower house chooses the prime minister and has virtual control of the budgeting process. In general, when the upper house makes a decision different from the lower house and when no agreement can be reached or when the upper house fails to take final action within a certain time, the decision of the lower house becomes that of the Diet. These are all general features of parliamentary forms of government similar to those found in all parliamentary systems.


3. Executive, parliamentary, and judicial relationships: US political system is based upon separation of powers which have checks and balances on each other, whereas Japan’s political system, which is similar to the British tradition, is based on the fusion of powers, stressing more cohesion between the executive and legislative functions. The tradition of consensus seeking is deeply rooted in Japan’s political culture which is collectivistically based. The head of executive power (the Prime Minister) is indirectly elected by the parliament and he is the leader of the majority party in the parliament who names a cabinet that runs the various state ministries and carries out the policy of the majority party. The cabinet is recruited from the Diet and is largely made up of senior members of the majority party or members of coalition parties in the absence of a one-party majority. Both the prime minister and the cabinet members are responsible to the Diet, and all ministers must resign en masse if the House passes a no-confidence resolution or rejects a confidence motion. All supreme court justices, except the Chief Justice who is designated by the cabinet and nominally appointed by the Emperor (a symbolic figurehead), are appointed by the cabinet without the disguise of a bow to the Emperor. The Supreme Court, however, like the U.S. counterpart, enjoys the power of judicial review and can declare the legislation unconstitutional.


4. Power structure: Japan is traditionally a centralized bureaucratic state modeled on the Chinese Confucian tradition and such a structure remains in today’s Japan. US is federal system, the state power protected by the constitution, and the states are more autonomous, whereas Japan is unitary system, local governments (47 prefectures or counties) and their policies are largely controlled by the central government and can be modified by the central government on the nationwide base. For example, local police and school issues are overseen by centralized administrative boards. Borrowing by local governments must be approved by the Ministry of Home Affairs, which is the national agency that oversees local governments.


5. Electoral system: after 1994, the House of Representative has 500 members. 200 are elected by the proportional representation system and 300 are elected from single-seat constituencies or single-member-district plurality system. The House of Councillors has 252 members who serve six-year terms, but half of the total number is elected every three years. That is to say, the Japanese electoral system is similar to that of Germany, which is a combination of plurality and proportional representative systems. In both houses, voters have two votes in elections, one for a party and the other for an individual.


6. Party system: The Liberal Democratic Party (LDP) used to dominate Japanese politics from 1955 to 1993, although many other parties did exist, such as New Frontier Party, Democratic Party of Japan, Japan Communist Party, Social Democratic Party, and other smaller parties. However, Japan’s one-party domination was shattered by the 1993 election, which produced no clear majority and therefore generated a coalition government of eight centrist, center-left, and leftist parties, even though voters gave the LDP the largest number of seats in the Diet (from 211 seats before 1996 to 240 seats in 1997). The once highly stable party system became a more fragmented and unpredictable multi-party system, but a broader representation is achieved.


Key features of Chinese political institution

1. Party/state/military are highly combined and intertwined into one, which is called “party-state”

2. The CCP basically leads and controls every branch of the state.

3. Government branches carry out the party policies and orders

4. Fusion of powers takes place at the Chinese Communist Party (CCP)

5. The party-state institutions make laws, and laws are defined in the Party’s ideology, norms, political goals, and policy needs. No independent judicial system.

6. No clear link between the top leaders and the people who are supposed to elect them. The politburo acts like the CEO, no check and balance systems in place.