Whereas British prime ministers can be unseated at a moment’s notice by simple majority vote, American presidents face no such threat.
Boris Johnson became prime minister last week after being picked by barely more than 92 000 members of his party who, as the Financial Times reported, make up a fraction of 1% of the United Kingdom’s electorate.
Actually, this process was a lot more democratic than the ones used in almost all previous choices of Conservative prime ministers between elections. When Andrew Bonar Law died in office in 1923, it was King George V who chose the commoner Stanley Baldwin rather than the glamorous Lord Curzon to replace him as he thought it no longer appropriate for the prime minister to sit in the House of Lords. The king said he wanted his prime minister to face his (Labour) opposition in the House of Commons every day.
In 1957, when Anthony Eden resigned after his Suez catastrophe, the present queen appointed Harold Macmillan to succeed him after a marquess and an earl called in cabinet ministers one by one to ask whether they supported him or his rival, ‘Rab’ Butler. Some of the ministers likened the experience to being ‘summoned to the headmaster’s study’.
Back in May 1940, Winston Churchill was appointed by King George VI on the advice of the resigning Neville Chamberlain after the alternative, Viscount Halifax, said he was not available, partly because he agreed that the prime minister should be a commoner and not a lord. Like Boris Johnson, Churchill became prime minister with a reputation near rock bottom. He was seen as lacking in trustworthiness, wisdom, and judgement. Only a year before, he had been the subject of a best-selling biography entitled Churchill, a Study in Failure: 1900-1939.
The first foreign leader to congratulate Johnson was Donald Trump, elected by 63 million American voters. This is a greater democratic mandate than Johnson’s. But the strength – the defining characteristic – of the British constitutional system is that it makes for perpetual accountability, which the American system does not.
No matter the size of their mandate, or whether they are appointed between elections or after an election victory, British prime ministers hold office only for so long as they can command majority support in the Commons. Chamberlain thus resigned to make way for Churchill after his support collapsed over his failure as a war leader. He actually won a vote of confidence; what forced him out was a backbench revolt that cut the Conservative majority from over 200 to only 81.
Sometimes even a cabinet revolt can do the job. Another failure as a war leader, Herbert Asquith, resigned in 1916 when his coalition cabinet told him it was time to go. At the end of 1990, Margaret Thatcher resigned after most of her Cabinet told her she had lost the support of the party.
The American system, more democratic in how presidents are elected, is deficient in its lack of mechanisms for accountability. British prime ministers have to be careful not to provoke cabinet resignations: at times even Churchill was scared of them. American presidents can hire and fire at will, with few political consequences.
Accountability to the legislature barely exists in Washington. Apart from participating in debates, British prime ministers often spend a great deal of time preparing for their question time in the Commons. American presidents usually deliver their state-of-the-union addresses to Congress in person, but otherwise they seldom go near Capitol Hill.
A hostile Congress can refuse to pass presidential legislation, even budgets. Congress can enact laws to put curbs on the White House or do all sorts of things the White House opposes. Congress can make life extremely difficult for a president even if he and the majority leaders in Congress belong to the same party.
But whereas British prime ministers can be unseated at a moment’s notice by simple majority vote, American presidents face no such threat. Once they have taken the oath of office upon their inauguration, they are untouchable. The only way they can be removed is by the process of impeachment and trial provided for in the Constitution.
However, as we saw again in Washington last week in the attempts of some politicians to bring about the impeachment of Donald Trump, this is a political process masquerading as a judicial one. It is arguably an abuse of the Constitution, although an inevitable one given the absence of any other means of getting rid of the president until the next election.
President Trump can probably ignore impeachment attempts (and even turn them to his advantage). Prime Minister Johnson, on the other hand, will be vulnerable to adverse votes in the House of Commons. The Commons has always sparingly used its powers to force out a prime minister. Mr Johnson will have to lead his party and manage the Commons with dazzling skill to ensure both a clean Brexit and his own survival.
Kane-Berman is a policy fellow at the IRR.
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