User:SimonP/Comparison of Canadian and United States governments

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The parliament buildings of Canada, known as Parliament Hill, in Ottawa, Ontario.

Though there are many similarities between the politics of Canada and the politics of the United States, there are also important differences. Many of the differences and similarities have formed the foundation for debates in the nineteenth, twentieth, and twenty-first centuries.^[1]

Origin of differences

There is much discussion, particularly in academic circles, of the differences and similarities between American and Canadian politics. There are a number of explanations for precisely why Canadian and American politics are different:

American Revolution and republicanism

Many people believe that the American Revolution brought about many of the differences between the United States and Canada, a view that has been the dominant one in most studies of Canadian history. With the establishment of the United States, the founders of that nation embraced republicanism, rejecting the Westminster system of parliamentary democracy. The republicanism that motivated Americans stressed independence, innovation, and an aversion to corruption, counterbalanced by a perceived need for devotion to civic duty. Many Americans (led by Thomas Jefferson), in charting a unique, "American" course, feared, and therefore rejected, a strong central government similar to that of the United Kingdom. Indeed, the "Jeffersonians" repeatedly denounced their federalist opponents, such as Alexander Hamilton, for being too tyrannical and undemocratic in character.

In contrast, Loyalists who fled the Thirteen Colonies during the American Revolution (given the title United Empire Loyalists in Canada) exerted a strong but not completely dominant influence in their new home. The Loyalists imported a degree of republicanism and democratic opposition to Canadian-style, British-influenced, colonial aristocratic traditions. They augmented an Anglophone population who chose a more pragmatic, non-ideological path. George Woodcock argued in The Century that Made Us: Canada 1814–1914 that Americans are revolutionaries, dedicated to an ideology they believe makes their country and their nation the "best" in the world and a beacon of democracy, while Canadians simply want chiefly to be left to their own traditions and loyalties, which, 141 years into its history as a nation, have diverged significantly in some ways from those of "Mother England," while in others, adhering closely to the British, monarchist, exemplar. Those diversions may have been influenced early on by the same Loyalists who supported the Crown; Lieutenant Governor Parr wrote, on March 8, 1788: "Whatever Loyalty these Lawyers may have brought with them from the States, is so strong tinctured with a Republican Spirit; that if they meet with any encouragement it may be attended with dangerous consequences to this Province. One of them (Sterns) aims at being the Wilkes of Nova Scotia."^[2] These fears were exaggerated, however, as the Loyalists were basically loyal to the Crown, and sought a role in the British Empire.

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 the key counterpart phrase in the Constitution Act, 1867, being "peace, order, and good government."

Fragment thesis

The fragment thesis, first advocated by Louis Hartz and later applied by Gad Horowitz 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 persecution 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 such as John Locke and the advocates of republicanism. By 1800 most of the English speakers in Canada were Loyalists who were defeated in the American Revolution and forced to move to British Canada, calling themselves United Empire Loyalists; French Canada comprised peasants loyal to an authoritarian and highly traditional Catholic Church. Thus, Canada's population was originally more conservative than the US. However, in the late 19th century, Canada was a destination of Eastern European socialists, British Fabians, and trade union members who have given modern Canada a somewhat 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 anti-American 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, advocated by Donald Creighton, ascribes the differences between Canada and the United States to a period much earlier than the revolution, arguing that the differences are based on contrasting trade patterns. While American 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 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 Roman Catholic Church dominated Quebec.

Both of these latter religious organizations were hierarchical in nature, leading, it is argued, to Canada's long standing predisposition to deference towards authority^{[citation needed]}. In recent decades however, the Catholic Church in Quebec has grown much weaker, and Canadians have been seen as less deferential to authority than they had been in the past. Methodists moved in large numbers from the United States to Canada in the early years of the 19th century, causing some alarm among conservatives who feared they also brought ideals that threatened the hierarchical Canadian system.

In 1827 Archdeacon Strachan's published his Ecclesiastical Chart. He complained "the teachers of the different denominations... are for the most part from the Unites States, where they gather their knowledge and form their sentiments; indeed the Methodist teachers are subject to the orders of the Conference of the United States of America, and it is manifest that the Colonial Government [cannot]... prevent them from gradually rendering a large portion of the population... hostile to our institutions, both civil and religious." British visitors were often shocked at the egalitarianism found in Canada; they decried "Republicanism," and the invasion of American attitudes. As Lower notes, the critics "rarely realized that equality was in the very essence of pioneer life."^[3]

Organized religion in the United States has since retained enormous strength, but with a weakening of the more liberal denominations, and a strengthening of the more conservative fundamentalist, evangelical, Mormon and Catholic elements. Organized religion in Canada has weakened and become more liberal, to the extent, some argue (including Michael Adams in his recent book Fire and Ice) that Canadians today are less deferential to authority than are Americans.

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 was developed by Michigan State University professor Gordon T. Stewart in his book The Origins of Canadian Politics: a Comparative Approach, where he 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 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.

Present differences

Constitutions

Both nations are governed under constitutions; Canada's is partly written and partly conventional, while the United States' is fully codified. The supreme interpreter of the constitutions of both nations are their respective supreme courts. However, the Supreme Court of the United States has a much longer history of constitutional interpretation than the Supreme Court of Canada. The Constitution of Canada consists of Acts of both the Parliament of the United Kingdom and the Parliament of Canada, but also, due to Canada's federalism, some Acts of provincial parliaments (such as the Legislative Assembly of Ontario). The Constitution was patriated in 1982, at which time the Canadian Charter of Rights and Freedoms and amending formulas were added.

Separation and fusion of powers

One fundamental concept among these differences is the contrast between the Canadian parliamentary system and the presidential system of the United States, including differences that arise from the concepts of fusion of powers and separation of powers. In Canada's system, the senior portion of the Cabinet Ministers are also legislators. The Ministers of the Crown, who advise the sovereign and the vice-regal Governor General on how to exercise the Crown's powers, are usually directly elected by their respective electorates (known as "ridings") as Members of Parliament in the Canadian House of Commons; although the head of state is not required to choose a cabinet from the House of Commons, he or she usually does. This means those responsible for executive actions also participate as legislators in the policy debates and lawmaking activities characteristic of the their roles as Members of Parliament.

The American President, by contrast, has no official role as a legislator, only enforcing and implementing laws passed by the legislative branch; though, the President, like the Canadian monarch or viceroy, may veto a bill passed by the respective legislators. The President participates in only occasional, informal, meetings with Representatives and Senators, and only officially addresses the assembled houses of Congress occasionally, most notably during the annual State of the Union address. Moreover, members of the President's cabinet are constitutionally prohibited from serving in Congress.

In Canada, the "checks and balances" are very different from those in the United States; it may be argued that the Prime Minister within Canada has more power than the American President does. Since Canada's legislative and executive branches draw from one another, the viceroy rarely exercises power without the guidance of the Prime Minister. This is only deviated from in instances brought on by, or the cause of, constitutional crisis. However, to ensure the stability of government, the Governor General must always choose as Prime Minister the person who has the largest group of supporters in the Canadian House of Commons. If a majority of the House votes against the government on a matter of confidence, the Prime Minister must either resign, recommend that the Governor General call an election, or be dismissed by the Governor General. The Prime Minister of a minority government is therefore in a far more precarious position than any American President, whose term is guaranteed by law. In the United States, there are often periods of cohabitation (more commonly referred to in the United States as divided government) where one or both houses of Congress are controlled by a different party than the White House is. The President also has limited control over the members of Congress and must often bargain for support there. This can sometimes lead to stalemates that greatly slow down the legislative process.

Among the reasons for the lack of control over legislators is the President's lack of control over the promotion of legislators or their membership in the party. By contrast, members of the Prime Minister's party who defy him or her put at risk any future promotion to executive office and even membership in the party. Losing membership in the party, among other things, makes re-election much more difficult at the next election.

The result of these differences is that primary responsibility for policy change is more divided in the United States than in Canada. For example, the Canadian Minister of National Defence is the driving force behind changes in defence policy. In addition to making regulatory decisions, he or she drafts legislation and shepherds it through Parliament. In contrast, the Secretary of Defense may make regulatory decisions, but he or she must contend with the chairs (and even the ranking minority members) of both the Senate Committee on Armed Services and the House Committee on Armed Services).

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 obvious who in government is responsible for any given issue. Unlike in the United States, the Prime Minister is wholly accountable for the economy, security and other national concerns.

President Bill Clinton, with Vice President Al Gore and Speaker Newt Gingrich, during the 1997 State of the Union address.

Both systems provide for an annual address to the legislature outlining the executive's program: the American State of the Union Address and the Canadian Speech from the Throne, or Throne Speech, read by the monarch or Governor General. The Throne Speech marks the official opening of every new session of parliament. It acts as a declaration, written by the Cabinet, of their goals for the upcoming parliamentary session.^[4] The State of the Union address stems from Article II, Section 3 of the American Constitution which states, "The President shall from time to time give to Congress information of the State of the Union and recommend to their Consideration such measures as he shall judge necessary and expedient." Since George Washington presidents have generally given either a speech or written message to the nation annually. Franklin Roosevelt was the first to refer to this annual address as the "State of the Union".^[5]

Federalism

Both nations have a federal system; in Canada the constituent units are known as provinces and territories; in the United States they are known as states and territories. There is also one US federal district — the District of Columbia – whereas in Canada the separation of the National Capital Region from its respective provinces into a similarly independent district has been proposed but never implemented. In both countries, arguably strong powers are accrued to the governments of the constituent states or provinces. The movement is referred to in US politics as "states' rights" while the term used in Canada is "decentralization."

Some consider the Canadian government to be more decentralized; Canada is one of the few countries in the world where the combined budgets of the provinces exceed that of the federal government, if one ignores transfer payments organized by the federal government. Canadian provinces are responsible for most of Canada's social safety net, including health care, welfare, and education. Others, however, counter that the Canadian government is actually highly centralized, due to the fact that the Prime Minister's Office controls a large amount of power within the government, as it is he or she who advises the monarch or viceroy on how to exercise their executive powers; by convention the monarch or viceroy must almost always follow the advice of his or her representative ministers. The Cabinet, as a committee of the Queen's Privy Council for Canada, may, by an Order-in-Council, also establish treaties, declare war, and is responsible for advice on the use of other executive powers by the Crown.

In the United States residuary or reserve power (i.e., power 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. In 1896 the Judicial Committee of the Privy Council ruled that the federal government could exercise its residuary power only to safeguard "peace, order and good government." The federal government lost its reserve power; thus, standards of social service soon varied widely from province to province. In order to reduce these differences, national programs in fields of provincial jurisdiction have gradually been negotiated between the federal government and the provinces, and, though the provinces retain other powers in the areas covered by national programs, the national programs are coordinated by the federal government, which largely finances them through transfers to the provinces; provinces may withdraw from these programs.

The provinces have exclusive jurisdiction in many fields which involve federal responsibilities in the United States; primary and secondary education being the most prominent. (Note: The states and municipalities in the United States also exercise some control over primary and secondary education.) Quebec is responsible for handling immigration into the province, and other provinces have the option of taking on the same responsibility for their jurisdiction. Quebec also collects its own corporate and personal income taxes. (Other provinces have their personal income taxes collected by the federal government, and all but Alberta and Ontario have their corporate income taxes collected by the federal government.) Quebec runs a pension plan parallel to the Canada Pension Plan; other provinces also have these options. In the United States education is primarily the responsibility of the states (although many public and private schools receive some federal funding) and all but seven states collect an income tax.

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 may make criminal 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. United States federal law enforcement agencies, such as the Federal Bureau of Investigation, become involved when criminal acts cross state jurisdictions. US federal law enforcement also work with the state and local police forces concurrently where federal and state laws have been violated. US states also operate their own militia referred to collectively as the National Guard.

In contrast to the federal Bloc Québécois and provincial Parti Québécois, who each promote Quebec becoming a new French-speaking, sovereign, nation state, there are no parties in the United States who dominate politics with the goal of separation from the USA. Puerto Rico, 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 very distant third.

Equalization payments

On the other hand, American grant formulas favor small states regardless of wealth; most grants ensure that a state receive between .5% and .75% of theSix of the ten provinces currently receive such payments;

idedAlberta are the only provinces that do not.

total grant money regardless of population or need.

Although these politics of "have" and "have-not" states are also present in America, 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. Federal taxation and wealth transfers do redistribute wealth between the "have" and "have-not" states, but primarily on an individual basis rather than statewide. Differences in cost of living between wealthier and less wealthy states creates controversy, as an individual living in a wealthier state may be forced to subsidize a resident of a poorer state, despite having a lower real income (but higher nominal dollar income).

Legislative branches

The United States has a bicameral legislature made up of the Senate and the House of Representatives. 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 with perhaps a few differences; only Nebraska has a unicameral legislature, the rest are bicameral. As with the United States, Canada also has a bicameral legislature made up of the Queen, the Senate and the House of Commons. Five Canadian provinces (Manitoba until 1876, New Brunswick until 1892, Nova Scotia until 1924, Quebec until 1968 and P.E.I. until 1893) originally had bicameral legislatures, however, they have eliminated their upper houses, and are now all unicameral.

The Canadian Senate is an unelected body that acts as a body of review or "sober second thought"; senators are appointed by the Governor General on the advice of his or her Prime Minister. The allocation of seats in the Canadian Senate is based on the relative equality of regions rather than individual provinces. Hence, unlike the elected US Senate, the Canadian upper house does not generally have a record of representing provincial interests, leading to calls for senatorial reform (see: Triple-E Senate).^[6]^[7] As Canadian Senators are appointed to serve until age 75, they tend to adopt a longer term view regarding legislation and have generally been more progressive in many ways than their elected counterpart the House of Commons.^[8]

Similarly, executive power is consistent between the states and provinces and the federal government in both countries; in Canada this stems from the fact that the sovereignty of the federal and provincial governments is passed on not by the Governors or parliaments, but equally through the Crown itself, meaning there are eleven legally distinct "crowns" within Canada, but only one monarchy. In American states the governors are similar in role to the President. In Canadian provinces the lieutenant governors represent the monarch as the Governor General does, and the provincial premiers (or prime ministers) are comparable to the federal Prime Minister.

link title====Political parties==== There are five political parties with seats in the Canadian House of Commons, and two in the US Congress. 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 example of Quebec or of the southern "Dixiecrats". The rise of the Bloc Québécois party and the decline of the Progressive Conservative Party drastically changed the political landscape of Canada. Before that, federal politics were dominated by two parties, as in the US; the Progressive Conservatives and the Liberals, though the Liberals held power for most of the 20th century, and were commonly referred to as "Canada's natural governing party" as a result. In contrast to the United States, Canadian third parties have consistently been able to get MPs elected into the Canadian parliament since 1921, at times forming informal coalition governments or supplanting one of the two main parties as Her Majesty's Loyal Opposition.

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. For example, in the 1997 Canadian federal election, the Liberal Party under Jean Chrétien won a majority of seats in the House of Commons despite winning only 38 per cent of the popular vote. These instances led some in Canada to demand proportional representation to create a more representative parliamentary system. In America, similar results can be produced by the presence of third parties or by the Electoral College.

In both countries it is rare for individuals to get elected from outside of one of the main established parties. In Canada, because of the parliamentary system, independent candidates can rarely aspire to much influence in government, or aspire to any high executive office, although exceptions occur in cases of minority governments, as in 2005. Likewise, in the United States 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 however played important roles in many presidential elections. In more modern times, the rise of the Reform Party of Ross Perot in 1992 and the rise of the Green Party in 2000 could both be said to have "split the vote", and thus exercised considerable influence. By contrast, new parties have been significantly influential in recent Canadian politics, with both the Reform Party and Bloc Québécois holding the status of Her Majesty's Loyal Opposition within a decade of their formation.

Despite the fact that the Canada features more political parties than the United States, the political culture of both nations and the lack of proportional representation tends to encourage broad-based coalition parties, rather than more narrowly-divided ideological parties, as found in many European states. The separate existence of the Progressive Conservative Party of Canada and the Canadian Alliance party was widely criticized by many members of the Canadian political right as a needless division, and the two parties eventually agreed to merge in 2003. Red Tories however, maintained that the new party was more in the mould of the American Republican Party than it was of the older Conservative tradition in Canada. The presence of the Red Tories and the NDP in Canadian politics remains the biggest key difference between Canadian and American political party culture, though it can be argued that views similar to those espoused by the NDP are held by a minority element of the Democratic Party, such as the "progressive" caucus. It is worth noting that the NDP has historically not held much influence at the national level, always placing a rather distant third (or more recently fourth due to the nature of first past the post) in national elections. Likewise, provinces in which the NDP has been elected to power, such as British Columbia and Saskatchewan usually feature only one major political opponent - if there are two or more major opponents to an NDP government then usually one will quickly dominate the other as NDP opponents will often rally around a common centrist or right-leaning alternative. This often makes provincial NDP parties more ideologically moderate than their federal counterpart.

Both countries have generally seen a shift in ideology towards the center in recent years, especially among parties of the left. Both Clinton-era Democrats and Chrétien-era Liberals have moved to dominate the center of the political spectrum, at the expense of harder left factions. This strategy has provided great long-term success for the Liberal Party of Canada, but less so for the Democratic Party of the United States. The collapse of Liberal support in Canada following the sponsorship scandal in 2003 and the drawback of Republican support following the page sex scandal in 2006 have slightly reversed those trends, leading to a resurgence in support for the left-wing NDP during the federal elections of 2004 and 2006 and the Democratic Party in 2006. On both the federal and provincial political arenas it has been commonly asserted that NDP supporters have in the past voted Liberal in order to defeat feared candidates of the political right, as happened in the Ontario provincial elections of 1999 and 2003 and the Canadian federal election of 2000.

In the United States, 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.

The two American political parties currently represented in the House of Representatives are:

the Republican Party, which held the majority of seats until the 2006 Congressional election
the Democratic Party, which won a majority of seats in the 2006 Congressional election

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

the Conservative Party, which won a minority government in 2006 and another minority government in 2008.
the Liberal Party, which held power from 1993 until 2006
the Bloc Québécois which is an exclusively regional Quebec party
the New Democratic Party (NDP), which is similar to a European social democratic party, with some 'green' elements, including strong affiliations with Canadian trade unions, the peace movement and ecology activists

Political parties are also represented in the senates of each country. The make up of these houses, however, is influenced differently; the Canadian Senate is an appointed body whose composition more-or-less reflects the amount of time prime ministers of certain political persuasions have governed, while a third the American Senate is popularly elected every two years.

The three Canadian political parties currently represented in the Senate are, in order of Senate population:

The two American political parties currently represented in the Senate are:

the Democratic Party
the Republican Party

Size of constituencies and campaign financing

The approximately 300 million Americans are represented by 535 elected federal legislators (435 members of the House of Representatives and 100 senators), or about 1 for every 500,000 people. Seats in the House of Representatives are currently apportioned so that the total always remains at 435 (as the 435 Representatives and the 100 Senators are at the upper limit of how many people a Congressional house could comfortably sit during a joint-session of Congress). This constraint is not part of the constitution but rather is a federal law that could be amended without consulting state governments, however the current law dates from 1911. In contrast, the approximately 32 million Canadians are represented by 413 federal legislators (308 elected federal Members of Parliament and 105 appointed Senators), or about one for every 80,000 Canadians of all ages. The number of seats in the House of Commons is readjusted every ten years, based on the results of the most recent census, however unlike the U.S., where House of Representative seats are reassessed every ten years after the U.S. Census, where some states may lose a representative and others gain one (and the total number is never allowed to fall below 435), various measures are in place to ensure that provincial seat totals cannot fall below certain historical levels of seats, thus making the Canadian system less responsive to changing demographic trends. Most of these provisions now form a part of the Canadian Constitution and could not be rescinded without the consent of the affected provincial governments, even if these provincial governments no longer had the population to justify their number of seats. In the current distribution of seats in both the U.S. House of Representatives and the U.S. Senate, the smallest U.S. state has one House representative and two Senators. Conversely, the smallest Canadian province, like Prince Edward Island, is divided into four electoral constituencies due to various Constitutional guarantees, and no province has lost seats in a re-distribution since 1968.

Each of Canada's three territories forms a single constituency. The District of Columbia, Puerto Rico and the territories send delegates to the House who have a voice, and vote in committees, but have no vote on the final passage of legislation. By contrast while the Canadian territories have just one territorial Member of Parliament and one Senator each, these are full voting members of their respective legislative bodies.

In the United States, elected politicians (at the state level) are directly involved in and responsible for the decennial process of boundary redistribution for both state and (except in the case of the seven least populous states) federal electoral districts. The federal government plays little role in the process of this boundary redistribution after setting the number of Representatives for each state, the only constraints coming from this level being that the populations of the districts must be as equal as possible, and that districts or portions thereof lying on the same landmass must be contigous.

Since state lawmakers undoubtedly have an interest electing friendly Representatives to the federal Congress this state of affairs frequently leads to accusations especially in the more populous states for federal that boundaries are gerrymandered to protect incumbent politicians or to defeat opponents by deliberately drawing boundaries to one party's advantage. There are also allegations and considerable evidence pointing to the existence of bi-partisan gerrymandering in some states, where state legislators from both parties seemingly agree to redraw boundaries in such a manner as to protect the re-election prospects of prominent federal lawmakers from both major parties.

While state legislatures (in the 43 states with multiple representatives) are obliged to redraw their House boundaries following each census, the Supreme Court has ruled there is nothing in the Constitution or federal law barring states from redrawing the boundaries at other times, provided the new boundaries stay within the constraints provided by the constitution. The controversial 2003 re-drawing of House boundaries in Texas was the action that prompted the Supreme Court ruling.

In Canada by comparison, adjustment of electoral boundaries is done by electoral boundaries commissions, in the federal case these being independent non-partisan bodies convened by the arms-length agency Elections Canada. Although allegations of gerrymandering still occur pundits in both countries generally agree that the practice is much less widespread (and certainly not as flagrant) in Canada, at least at the federal level. The federal government is responsible for ordering each re-distribution and there is no Constitutional or legal provision regarding how often the boundaries must be re-drawn. In practice, re-distributions have been conducted on average once every other census, in other words once per decade since Canada holds a census every five years.

American candidates for the United States Senate 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, most of which are compact (only in the far north does sparseness of population create large ridings). Urban ridings in Canada can cover as little as 9 km² (about 3½ sq. mi.).

Neither Canadians nor Americans vote directly for their head of government. Instead of directly voting for the Prime Minister, Canadians vote only for their local candidate. In practice, the major party leaders are obliged to campaign nationally on behalf of their parties. Likewise, voters in the United States vote only for the electors who will represent their state in the formal election. These electors are pledged to a specific ticket but are not always legally obliged to vote for the candidates they are pledged to.

The effects of these differences 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. As a result, there are far fewer legal constraints on American campaign financing compared to most other developed democracies.

Canada, starting with the federal election of 2004, has introduced party funding reform, strictly limiting 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.

The rigid control of Members of Parliament in Canada is also said to discourage corruption and reduce the influence of money on Canadian MPs. Unlike American Senators, and even Representatives, MPs do not need to raise great deals of money, and because they are far less powerful there is less interest from corporations to donate to them. By contrast the perceived 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 or a disadvantage.

Judicial system

The membership of the federal judicial branch in Canada is also closely controlled by the Prime Minister, who gives the final advice for the Queen-in-Council's appointment of Supreme Court judges. In the United States, by contrast, all judicial appointments must be approved by the Senate. In an effort to democratize the Canadian system, borrowing from the American example, a process of convening a multi-party committee to publicly review Supreme Court appointments in Canada was established. However, the committee holds no power to prevent the Prime Minister from making his recommendation, as is his constitutional right, unlike the American Senate.

Judicial activism has been a concern in both countries. However, prior to 1982 , the Canadian judicial branch was far less powerful than the American 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. This has never been used by the federal government, however, and the Supreme Court has ruled that the clause does not apply to civil law.

Bureaucracy

A key, and often unnoted, difference between Canada and America is the role of professional bureaucrats. In both cases officials are appointed by the chief executive; however, in Canada, because the Crown is apolitical, very few appointed officials lose their jobs during a shift of government, even to a new party. This creates different dynamics, most notably in the conduct of Ministers vs. Secretaries: a 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. In America, by contrast, over 2500 jobs are direct appointments of the President, cabinet ministers are not drawn from elected Members of Congress, and the top rank of each federal department is replaced following each presidential election.

An American Cabinet Secretary always takes one job for the duration of the Administration, unless they are replaced or resign from the government entirely, and must be confirmed by the Senate, a process considerably less automatic than in Canada since the Senate may be controlled by the opposition party. Cabinet Secretaries are generally specialists in their fields, and have great power to replace their assistants, which extends considerably farther down into the agencies they control than in Canada. Originally, nearly all civil service positions were assigned by patronage. However, since the Pendleton Civil Service Reform Act of 1883, the majority of the civil service, especially at the lower levels, is appointed by merit and belongs to the American Federation of Government Employees labor union. These jobs of these employees, like in Canada, are not dependent upon election results.

Multilateralism

Due to Canada's much smaller political and military size in relation to the United States, Canada has had little opportunity to act unilaterally, and is largely committed to the concept of multilateralism and collective security. After rejecting a major role in the League of Nations in 1935, it later became one of the strongest backers of the United Nations and the Commonwealth, and supports most international initiatives, such as the International Criminal Court, and the International Ban on Land Mines. the United States pursues both unilateral and multilateral policies at different times. Both Canada and the United States are committed to international economic organizations such as the International Monetary Fund, the World Health Organization, the World Trade Organization and the World Bank.

Notes

^ Warner (1960)
^ Clark, 132
^ Lower; p. 202
^ "Speech from the Throne Frequently Asked Questions". The Government of Canada. 2007-10-16. Retrieved 2008-01-11. {{cite news}}: Cite has empty unknown parameter: |coauthors= (help)
^ "History of the State of the Union". The Whitehouse. Retrieved 2008-01-11. {{cite news}}: Cite has empty unknown parameter: |coauthors= (help)
^ "A Legislative and Historical Overview of the Senate of Canada". THE SENATE OF CANADA. 2001-05. Retrieved 2007-08-01. {{cite news}}: Check date values in: |date= (help); Cite has empty unknown parameter: |coauthors= (help)
^ "Challenges in Senate Reform" (PDF). Fraser Institute. 2004-09. pp. 16–17. Retrieved 2007-08-01. {{cite news}}: Check date values in: |date= (help); Cite has empty unknown parameter: |coauthors= (help)
^ "THE CANADIAN SENATE IN FOCUS". THE SENATE OF CANADA. 2001-05. Retrieved 2007-08-01. {{cite news}}: Check date values in: |date= (help); Cite has empty unknown parameter: |coauthors= (help)

References

Adams, Michael. 2003. Fire and Ice: The United States, Canada and the Myth of Converging Values. Toronto: Penguin. ISBN 0-14-301422-6. Reviewed by W.S. Neidhardt, Canadian Social Studies, V. 39, No. 2, Winter, 2005.[1]
Christie, Nancy. "'In These Times of Democratic Rage and Delusion': Popular Religion and the Challenge to the Established Order, 1760-1815" in G. A. Rawlyk, ed.The Canadian Protestant Experience (1994)
Clark; S.D.Movements of Political Protest in Canada, 1640-1840 University of Toronto Press. 1959.
Errington, Jane The lion, the eagle, and Upper Canada: a developing colonial ideology McGill-Queen's University Press, 1987.
Grabb, Edward, James Curtis and Douglas Baer; "Defining Moments and Recurring Myths: Comparing Canadians and Americans after the American Revolution" The Canadian Review of Sociology and Anthropology, Vol. 37, 2000
Lipset, Seymour Martin. Continental Divide; The Values and Institutions of the United States and Canada (1990)
Lower; Arthur R. M. Canadians in the Making: A Social History of Canada Toronto. 1958.
McNairn, Jeffrey L. The capacity to judge: public opinion and deliberative democracy in Upper Canada 1791-1854 Toronto: University of Toronto Press, 2000.
McNairn, Jeffrey L. "Publius of the North: Tory Republicanism and the American Constitution in Upper Canada, 1848-54." Canadian Historical Review 1996 77(4): 504-537. ISSN 0008-3755
Moffett, Samuel E. The Americanization of Canada (1907)
Schwartz, Mildred. Party Movements in the United States and Canada: Strategies of Persistence (2005)
Smith; Allan. "Doing the Continental: Conceptualizations of the Canadian-American Relationship in the Long Twentieth Century" in Canadian-American Public Policy 2000. pp 2+
Allan Smith, Canada—An American Nation? Essays on Continentalism, Identity, and the Canadian Frame of Mind (McGill-Queen's University Press, 1994)
Goldwin Smith, Canada and the Canadian Question Toronto: 1891, numerous reprints
Stewart, G. 1992. The American Response to Canada Since 1776 Michigan State University Press.
Stewart, G. 1986. The Origins of Canadian Politics: A Comparative Approach
Thompson, John Herd and Stephen J. Randall, Canada and the United States: Ambivalent Allies McGill-Queen's University Press, 1994
Warner, Donald F. The Idea of Continental Union: Agitation for the Annexation of Canada to the United States, 1849–1893 (1960).

External links

Department of Canadian Heritage: Comparison With Other Systems of Government

[1] Warner (1960)

[2] Clark, 132

[3] Lower; p. 202

[4] "Speech from the Throne Frequently Asked Questions". The Government of Canada. 2007-10-16. Retrieved 2008-01-11. {{cite news}}: Cite has empty unknown parameter: |coauthors= (help)

[5] "History of the State of the Union". The Whitehouse. Retrieved 2008-01-11. {{cite news}}: Cite has empty unknown parameter: |coauthors= (help)

[6] "A Legislative and Historical Overview of the Senate of Canada". THE SENATE OF CANADA. 2001-05. Retrieved 2007-08-01. {{cite news}}: Check date values in: |date= (help); Cite has empty unknown parameter: |coauthors= (help)

[7] "Challenges in Senate Reform" (PDF). Fraser Institute. 2004-09. pp. 16–17. Retrieved 2007-08-01. {{cite news}}: Check date values in: |date= (help); Cite has empty unknown parameter: |coauthors= (help)

[8] "THE CANADIAN SENATE IN FOCUS". THE SENATE OF CANADA. 2001-05. Retrieved 2007-08-01. {{cite news}}: Check date values in: |date= (help); Cite has empty unknown parameter: |coauthors= (help)

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