Which do you consider to be the more powerful chief executive in his or her own country: The British Prime Minister or the President of The United States?

The British PM and the American President operate within different political frameworks. To draw comparisons we must look at these frameworks and determine the contexts under which both figures must govern. Yet before we do this it is important to note that chief executive power can be loosely defined as the ability to influence other branches of Government. Therefore the extent to which each chief executive can do this is the key to answering this question.

The most important issue to look at first is the structure of Government in the respective countries. In Britain a fusion of powers exists. The three branches of Government (Executive, Legislature and Judiciary) are merged. The executive branch (the government) can exercise direct control over the legislative branch (parliament). Therefore the executive branch can formulate policy and force the legislative branch to accept it. This has become known as an elective dictatorship and the Prime Minister stands at the apex of this.

In contrast, the United States operates a separation of powers. The three branches, as the name suggests, are separate bodies with their own autonomy. The President and his staff constitute the executive branch of Government, who in modern times are mainly responsible for initiating policy. However, Congress (the legislature) is given constitutional responsibility for making policy. This is a severe limitation since the President is only able to submit proposals, which can easily be rejected, or at best modified, by Congress. Unlike the Prime Minister, the President cannot coerce a stubborn legislature to submit to his will. In addition, the Supreme Court has the power to strike down legislation as ‘unconstitutional’, restricting the President’s options even further. For instance, neither the President nor the Congress can ban gun ownership because the constitution’s second amendment guarantees ‘the right to bear arms’. Unlike its counterpart in the UK (the House of Lords), the Supreme Court is not a passive body.

This leads nicely to the next issue: what are the constitutional limits to executive power? In Britain PM Tony Blair has only an unwritten, uncodified constitution to contend with. What this means is that there is an absence of a clear document detailing the Government’s functions and limits. This, further strengthening the PM’s hand, inadequately protects human rights. Parliament theoretically may pass any law it chooses, disregarding civil liberties at will. No body exists that is able to declare such acts unconstitutional. Indeed, A.V Dicey identified ‘parliamentary sovereignty’ as a pillar of the British Constitution. This means that parliament is supreme; rendering the judiciary as a body that merely applies laws made by parliament itself. In turn, parliament is said to be dominated by the Prime Minister.

In contrast, The American President is severely constrained by a written, codified constitution. This results from the Founding Fathers’ suspicion of tyrannical rule. Indeed, prior to the War of Independence, the British monarch dictated the American people. This spawned great suspicion of power concentrated in the hands of the few. As a result, Article II of the constitution is vague and evasive in its description of the President, granting him little power other than that of ‘executive power’. The few powers that were granted are as follows:

As I have illustrated, there are considerable checks on the ...

This is a preview of the whole essay

As I have illustrated, there are considerable checks on the formal powers of the President. Nevertheless, the office remains open to political initiative. According to Richard Neustadt (1960) the President’s main power is that of persuasion. He can only persuade Congress to subscribe to his way of thinking.

Other theorists argue that the President can do more than that, labelling the office a ‘bully pulpit’. Reagan was known to use these tactics in his first term in office. He wanted to force through his right-wing budget proposals and appealed directly to the public to do so. He urged people to write to their local representative, who serves only a two-year term, in favour of them. The representatives, with another election impending, were then more open to Reagan’s proposals. The result was a victory for Reagan, who saw many of his proposals become law.

Furthermore, emergency powers exist and are inherent within the presidency. Abraham Lincoln was the first to invoke them during the civil war, suspending habeas corpus (bringing a person before court to investigate the authorities’ right to keep him imprisoned) in some places and raising armies without congressional support. Franklin Delano Roosevelt (1933-45) followed with his New Deal legislative programme that arguably contravened the constitution, but was necessary in the adverse climate of the depression era. Similarly, President Bush Jnr in the wake of the current terrorist crisis has forced through the use of taps on phones that arguably infringe human rights.

However, the President is still weak in comparison with the UK Prime Minister. Unburdened by a written constitution, the PM has a formidable array of powers. He is both head of Government and leader of his party, with enormous powers of patronage. For instance, within his own Cabinet, the PM has the power to hire & fire, promote and demote. In addition the PM can determine the size of the Cabinet and which jobs are to be in it. Indeed, Ministries and Cabinet positions can be combined, created or abolished e.g. Tony Blair created the position of Deputy PM for John Prescott in 1997.

Richard Crossman proposed the idea of the PM as an all-powerful figure in 1960, which became known as the Presidential model. He argued that the PM could dominate all areas of policy and intervene in any department that he chooses. He continued to say that the Cabinet could be routinely subordinated and even ignored. So much so that it is a ‘dignified’ part of the constitution such as the Lords and the Monarchy. Indeed from this perspective, Cabinet has been reduced to a mere rubber stamp through the notion of collective responsibility. This states that all Ministers must defend a decision publicly or else resign from Government. Crossman argued that this had become a demand for collective obedience and a means of strengthening the PM’s hand.

Margaret Thatcher best illustrates these tendencies. She routinely intervened in Ministerial departments, appointed right-wing free marketers (dries) to the Cabinet and held fewer meetings. Instead, she used what is known as a kitchen cabinet (loose and informal policy advice group) to formulate policy. In short, she created a cabinet that was a puppet of her string.

The further advantage the PM has over his US counterpart is a relatively weak legislature. The PM, as leader of his party, presides over a majority in the legislative chamber, the House of Commons. Through the use of whips, the PM can force his MPs to vote his way on a particular issue. Since his party hold a majority, the PM is likely to get his way. This has become known as an elective dictatorship.

The US President however, is less fortunate and suffers almost impossible constraints. This is what Hodgson (1980, p13) describes as the ‘paradox of presidential power’. That is the image of leader of the free world juxtaposed with a weak constitutional position. As I have already mentioned, Congress has the responsibility for law making and the President can only persuade. Therefore the President is a prisoner of unrealistic expectations and often cannot meet the promises made during the election campaign. Also, unlike the PM, the President cannot command support in the legislature. Congressmen are elected independently of the President. This combined with a de-centralised party system places the President in a weak position.

This may lead to Presidential frustration and unconstitutional activity. For instance, Richard Nixon committed a number of offences in his presidency such as the impoundment of money and misleading Congress in relation to the war in Cambodia. His most notable offence however was the authorisation of the robbery and bugging of Democrat offices, which became known as Watergate. Richard Pious describes this as the ‘overshoot and collapse’ of Presidents intent on adopting prerogative (informal) powers to the extreme. This viewpoint derives from the fact that Congress was about to impeach (remove from office) Nixon before he resigned. Again this illustrates the powerful nature of the legislature that even a strong, ‘imperial’ US president must face.

Nevertheless, the UK Prime Minister is also subject to limitations. It is important to note at this point that Margaret Thatcher was forced to resign by her own Cabinet, which gives rise to the debate concerning Cabinet Government. This states that the political system limits a PM’s power. Since a PM relies upon the support of the majority party in Parliament, he must impress his MPs and not batter them into submission. Indeed, whips are not always powerful. This is especially true to MPs who have retired from senior posts and no longer have ambitions of gaining promotion. For instance, retired Prime Minister Edward Heath slotted into this category and as such could not be coerced by the whips. Instead, a mere appeal to party loyalty had to suffice.

From this perspective, the power of patronage is also overstated. Some figures cannot be ignored and can demand a position in the cabinet. For instance, Tony Blair could never sideline Gordon Brown. Therefore in short, the PM is chair of a committee without whose support he is ineffective.

John Major typifies this approach, which was seen as a pragmatic style of leadership in face of a small majority in the Commons. He would hold consensual cabinet meetings but was nevertheless criticised in the media for being weak, ineffective and directionless. In 1997 he subsequently lost the election. This proves that the media is an effective constraint on Prime Ministerial power.

The different styles of Thatcher and Major illustrate that the personality of a chief executive and circumstances they must face are important in determining their power. The office of the Prime Minister is powerful indeed under the right leadership, but under weak leadership its inherent powers can be wasted. Both Asquith (1908-16) and Neville Chamberlain were obliged to leave office because they were unable to provide dynamic leadership in the face of war. This also illustrates the importance of circumstances. For instance, Thatcher’s popularity was boosted by the Falklands conflict in the 1980s, yet Tony Blair was weakened by the foot and mouth and fuel crises of 2000.

In the United States, the amount of legislative success a President can achieve varies greatly in accordance with his personality and circumstances. For instance, President Kennedy proposed his great society programme in the early sixties but failed to get Congress to pass it. After his assassination, Lyndon Johnson took over and achieved success where Kennedy failed. The reason for this was Johnson’s intimidating demeanour and considerable experience in Congress, which allowed him to manipulate the body in a way that Kennedy could not. This proves the importance of different people with different skills.

Therefore to conclude neither Chief Executive is without constraints, although the UK Prime Minister is certainly the more powerful within his or her own country. He is not constrained by an assertive judiciary or legislature like his American counterpart. Furthermore the UK doctrine of parliamentary sovereignty means that parliament can make or unmake any law it chooses, a body that is in turn dominated by the Prime Minister. His strength is reinforced further by the lack of a codified constitution, which means that the role of the PM is ‘what the office holder chooses and is able to make of it’ (Asquith 1908-16). The American President however, enjoys none of these advantages. His power is that of persuasion, which if used effectively, can significantly influence policy direction. The use of the veto is his most powerful weapon since it is difficult to override.

2,085 words.