Pax Americana meets Pax Europaea. Comparative study of … · 2018-08-20 · Karol Chwedczuk-Szulc, University of Wrocław, Poland Pax Americana meets Pax Europaea. Comparative study

Karol Chwedczuk-Szulc, University of Wrocław, Poland

Pax Americana meets Pax Europaea. Comparative study of compound polities in

crisis: the United States and European Union

First draft – please do not cite without permission of the Author.

ABSTRACT

The process of European integration is commonly described as “in crisis” and “at the crossroads”.

The scope of the EU’s problems is so broad and the time has come for decisions about the future

of the European Project. The main questions in the public discourse of the EU revolve around the

dichotomy: should the EU ultimately constitute a loose association of states or should it become

the United State of Europe? In either case, the history and practice of American federalism seem

to be self-evident material for a comparative study, which is the main aim of the project. Political,

cultural, social, economic analogies and/or dissimilarities constitute research material for the

project.

Keywords: social constructivism, US-EU comparative studies, collective habitus,

supranationalism, federalism, process-tracing.

Background

The process of European integration is commonly described as “in crisis” and “at

the crossroads”. The scope of the EU’s problems is so broad that there is a relatively wide

consensus among experts and observers that the time has come for decisions about the

future of the European Project. The main questions in the public discourse of the EU

revolve around the following dichotomy: should it ultimately constitute a loose

association of nation-states, cooperating economically in a globalised world, or should it

rather become the United States of Europe, a federal-like republic? In any reflection on

European integration, the history and practice of American federalism seems to be self-

evident material for a comparative study, which is manifested by rich literature on the

topic (Tortola, 2014). Political, cultural, social, economic and historical analogies and/or

dissimilarities create a body of comparative knowledge on both political entities.

The EU is often described as an unprecedented political project, an entity sui

generis (Boşilcă, 2014). It is worth noting, however, that the USA was described in the

Karol Chwedczuk-Szulc, University of Wroclaw, Poland

same way, especially at its beginnings (Sbraiga, 2006). The basic rationale behind this

very project is that the story of American political development offers suitable

comparative material for the story of the EU. With this premise, I intend to trace the

development of political cleavages within these compound polities, to investigate how

they evolved over time, and to inquire into how the solutions reached in the American

case might be applicable to the EU. Of course, I am aware of significant differences

between these two polities, and that is why the project is entitled “Pax Americana meets

Pax Europaea” (confer Kagan, 2003). My argument is that in the middle of the 19th century,

the American project found itself in a predicament broadly comparable to the European

predicament today. In the American case, it took the Civil War to provide a forceful

resolution of the growing tensions. Such an outcome seems highly unlikely in the case of

the European Union, given how it has left the final decision about membership to its

members and their societies (e.g. commencing Brexit). It corresponds well with the

perception of the USA as a superpower in terms of hard-power (military, economy) and

the EU is described as a “soft-power/normative empire” (culture, values, good

governance [Del Sarto, 2015]). My general argument, therefore, is that both polities are in

some aspects similar and in some, different, and they combine both general approaches

in comparative research (comparing similar units vs comparing different units).

The biggest challenge, but also one of the greatest added value of my project, is that the

USA is already a well-defined and developed polity, while the EU is still developing and its

future is open-ended. On one hand, this poses a problem: what processes, institutions,

practices and events to compare exactly? We already know the results of a given process

of development in the case of USA, but not in the case of the EU – a federal state in the

making, at best. On the other hand, this is exactly the aim and added value of the project,

namely, to identify the most important trends of the political history of the USA and the

EU and compare them, see what solutions were chosen in the American case and how we

can correlate them with the current crises and decision-making in Europe. I am aware

that the research objective is defined ambitiously and requires a considerable amount of

resources (time and money, most of all). Therefore, the project is a part of a broader

research agenda. In a formal dimension, the project feeds into the plan of a book under

the same title: Pax Americana meets Pax Europaea. Comparative study of compound

polities in crisis: the United States and European Union.


Objectives

I intend to focus on the major crisis moments that happened in the history of both

polities. In today’s EU, current crisis/es are being framed as the most significant in history

and I will treat them in this manner. In the USA, the most severe political crises resulted

in the Civil War1. These are the moments around which I would like to centre my analysis.

The research procedure will involve a process-tracing method. The point is to identify

long-term historical processes, leading to the political crisis and a systemic breakthrough

that followed (Leder, 2014). Next, I will scrutinize the solutions adopted as a result of the

breakthrough and the effects that they produced.

At this preliminary stage of the research, it can already be stated that the main

issue, both in the case of the USA and the EU, will be the conflict between the centre

(federal government, European institutions) and the elements constituting the compound

polity (member states). The conflict revolves around the issue of contestation of centrally-

exercised power by the members of the unions. A very interesting attempt to compare the

contestation mechanisms in the USA and the EU was undertaken by Glencross (2009),

who compares the conflict between the central government in pre-Civil War in the USA

with the problems faced by the process of European integration. One of the main

arguments supporting the thesis that the EU is a viable project after all is exactly the fact

that in the EU there is a legal mechanism of secession, whereas this feature was (and still

is) absent in the American system. My analysis will not only focus on the issue of political

power bargaining, but will also encompass such areas like: economy (slavery based

agriculture vs free industrialist society and developed market-based economies vs post-

communist economies), society (traditional, pre-industrial vs modern, industrial and

post-modern vs modern), geography (North vs South and West vs East), religion, culture

and the legal system. All these areas constitute the common space of a given polity,

therefore, they will not be analysed separately but holistically, as mutually co-

constitutive. I consider the possibility that during the research procedure, it may appear

1 Although at this stage, I intend to treat the Civil War in the USA as a crisis moment, as the main reference point, I am aware that after the initial stage of the research a different moment of the American political development may appear to be more productive in terms of comparison with the European Union. For example, it was pointed out to me by some experts that it may be also worthwhile to compare current EU’s situation with the era of progressivism in the early 20th century in the USA. Nevertheless, the choice of the Civil War seems justified, as the character of the United States definitely changed afterwards, into the direction of one, sovereign country, which was reflected in the name of “United States” which began to be treated as a singular form, not plural anymore.


that the extent of the planned project is simply too broad. Hence the option of limiting the

number of areas taken into account is a viable one. Nevertheless, because of the

theoretical framework adopted in the project, I prefer a more inclusive and broader

approach. This implies, in turn, that all of the areas or fields will at the end be integrated

into quite general categories of presenting collected data.

Taken into account all of the above, the main research questions are:

• What were the main cleavages within the compound polities?

• How were the main cleavages in both compound polities internalized into the

political systems in the respective efforts to overcome them?

• What were the main elements/obstacles preventing the polities from a successful

containment of cleavages?

• How did the cleavages and the efforts to contain them shape the political practices

and habitus within the polities?

The secondary research questions are to be developed during the following stages of

the project. In general, the project is positioned within such disciplines of social sciences

like international relations studies, historical sociology, comparative studies. Some initial

selected hypotheses are:

• The main cleavage between the central government and a member state is about

power distribution between them.

• The main difference between the process of integration of the USA and the EU is

that the former can be described as a bottom-up project, and the latter as top-down

project.

• Citizens’ opposition to the centralization of power in the USA was/is the result of

political ideologies. In case of the EU, it is mainly the result of a clash between

national and supranational identities.

Theoretical framework and methodology

The main research questions, especially the last one, suggest the appropriate

theoretical framework for this project. At the meta-theoretical, paradigm level, I accept

the premises of social constructivism. Constructivism does not deal with the question of

a research subject, of what one should research. Instead, this paradigm can be reduced to

its core axiom, which is a dogma-like statement: the social world is socially constructed


(Barnett, 2011). Therefore, it is rather a meta-theory/paradigm posing “why” and “how”

questions, not “what” (Merton 1968). It focuses on the processes of meaning and

intersubjective knowledge creation, not so much on reifications of given concepts2. The

theory, in the proper meaning of this word, that I want to adapt for the use of this project

is the practice theory (Bourdieu 1984; Otner, 2006; Giddens; 1986; McCourt 2016;

Schatzki, Cetina, Savigny, 2001; Wendt 1995; Adler and Pouliot 2011; Jackson and Nexon

1999). The main point of focus in this theory is relations between human (agent) activity

and the system. The relation between these two is mutually reciprocal, as both the system

and the agent shape the behaviour of an actor and the system. The key terms for the

practice theory adopted for the use in this project are: the field, habitus, doxa and the

cultural capital (Bourdieu, op.cit.).

The added value of this theoretical approach is that it will allow for a coherent

research procedure both in the case of the EU and the USA. First, it will focus on identifying

the spheres of main cleavages (fields) between the central/federal government and

member states. Next, the values internalized in the public sphere as obvious (doxa) will

be named. And finally, how given groups (religions, political elites, parties, ethnic groups)

form the system of collective dispositions and practices (habitus). These concepts will

form a framework of analysis between the USA and the EU. The content (semantic,

cultural, political etc.) will be different in both cases and this exactly constitutes the core

of the comparative study. The same concepts, with a possibly semantic differences will be

compared, producing relevant conclusions and knowledge. The dispositions and practices

conceptualized as habitus are durable structures, shaped in a long, historical process. This

is the reason why the general methodological approach to the concepts under scrutiny is

process tracing. The usefulness of this approach in projects stems from the fact that it

focuses on discovering strong causal relations in the long-term, basing on real-world case

studies. The point is to uncover and describe the mechanistic evidence behind the studied

process. The approach to data may be compared, with the one used in a grounded theory.

The first step is to describe categories (causal relations within process) and then to

saturate them with dense, empirically acquired data (Beach, 2017; Bryant, 2002).

2 In this understanding, social constructivism does not include or exclude any concepts and does not state which of them are true or not. It may as well operate with such concepts like “self-help”, “state-centrism” or “anarchy”, but it will focus on the process of their meaning production and reproduction. Just like Alexander Wendt did with “anarchy” in his classic article “Anarchy is What States Make of It” (Wendt, 1992)


While the theoretical framework presented above can be labelled as “grand

theorizing”, mid-range theoretical assumptions explaining the dynamic between different

polities are also to be used. The two of them that I would like to apply are” “inclusive” vs

“extractive” political institutions developed by Acemoglu and Robinson (2012) and

“limited access orders” vs “open access orders” of North, Wallis, Webb and Weingast

(2007). Basically, both concepts present the two dimension of the problem that one can

observe in both compound polities, the USA and the EU. On one hand, we have political

orders/institutions that are open, democratic, based on the competitive free-market,

inclusive, with full, state monopoly on violence, where violence is manifested in the form

of a political conflict. On the other hand, we have polities that are closed, following a non-

liberal version of a democratic rule of law, with a high level of state interventionism in the

economy, elitist and extractive towards less powerful parts of the society and the state

monopoly on violence is not guaranteed, which results sometimes in violence within the

society. Tensions appear, when these two types of political orders try to integrate,

resulting in the opposition of the extractive and limited access orders. Just as it happened

in the antebellum USA and is happening right now in the EU.

The research methods designed for the above described objectives include:

• Desk research. Especially important at the preliminary stage of the research. The

aim is mainly descriptive and exploratory. It should identify the main research

subjects, i.e. practices, dispositions, mechanisms, political actors and crucial

events.

• Critical text analysis. Aimed at uncovering the process of social construction of

doxa.

• Computer assisted text analysis (CATA). The same aim as in the case of a critical

text analysis, used for the analysis of a big portion of the material, e.g.

Congressional Records or media outlets. It is significant because it will provide a

socio-historical dynamic perspective on the processes under scrutiny.

• In-depth interviews. This method is important both at the initial stage, as

exploratory research, but also at the end of the research, as data analysis and

reduction. Interviews are to serve, additionally, as a triangulation of the methods.

Significance


I am deeply convinced that the presented research project would advance my research

interests that I started already two years ago (research grant of the Kosciuszko

Foundation, “American Federalism and European Integration in Social Perspective”). I am

also confident that my project will contribute to the integration of the available literature

comparing and contrasting the evolution of American and European federalism.

As studies show, a vast majority of the scholarly articles in social sciences are not cited

even once (sic! [Bok, 2015]). Therefore, it is of crucial importance to integrate the huge

amount of data available, to make it more accessible for the community of scholars and a

wider public. Additionally, my project will foster a comparative study of the two cases,

empowering a transatlantic dialogue and an exchange of ideas. Moreover, I believe that

the findings from this project will prove useful for policymakers, in so far as its results

could uncover deep and structural connections between the United States and the

European Union. The produced knowledge could contribute to the discussion taking place

right now about the future path of the European integration.

Research framework: categorization of longue durée3 tendencies

In this section of the paper, I would like to point out the most important tendencies that

have constituted the shape of both compound polities and were/are processes of long

duration. The aim is to identify the phenomena for process-tracing method, making it

possible to draw conclusions about similarities and differences of these processes in the

EU and the US. The most important task of this part of the research is to establish the

components of the comparative research that are in tune with each other in terms of their

essence, category or form. It is also important to be aware which tendencies identified

here will be put under the label “similar” and which should in the “different” set. This

initial part of the research is based mostly on the critical text analysis method, where I am

trying to identify these elements of each tendency that will be next put into the “field,

habitus, doxa” scheme.

The tendencies that I treat as comparable in terms of my research are:

3 I am using this concept of the French Annales School to describe long-lasting socio-political tendencies in the US and the EU that have led to the Civil War/crises. F. Braudel (2009), “History and the Social Sciences: The Longue Durée”, Review 32:2, New York: Research Foundation of State University of New York


• Ideological and political cleavage between federalists and confederalists. To put it

simply , federalists are the people who would like to see stronger central/federal

governmental institutions at the expense of member states of the compound polity,

and the confederalists views on the issue of power distribution are exactly

opposite.

• Conflict between inclusive and extractive political institutions and between limited

access orders and open access orders, as explained earlier.

• Belief in own exceptionalism. Both polities are to a greater or lesser extent

convinced that they are one of its kind, sui generis polities, responsible for the

spread of grand ideas that can make the world a better place.

o Expansionism stemming from the conviction of exceptionalism.

• Institutionalisation of integration oriented towards federalisation.

o Special role of integration with the use of law.

• Process of identity creation: multilevel identities, between member states and the

union.

• Influence of external environment.

In my opinion, the comparison of the antebellum US and the EU is more viable than a

possible comparison of the EU with post-Civil War US, mostly because of the structural

and legal changes in the US, resulting from the war. First, at least formally, the question

whether the US is a federation or confederation was solved, in favour of the former.

Second, the United States become a singular form of country’s name – an emanation of the

change marked in the first point. Third, the Civil War itself was necessarily an end (though

only a formal one) of a long-lasting tensions between dividing tendencies, which was

decisive for the future of the United States as a polity4.

I am aware that these three arguments are of a general nature, nevertheless, I think

that they show the main idea behind the whole project. The main assumption is that the

EU has reached such a level of both internal and external tensions that the structural

change is inevitable – a change that will define the future of this supranational

organisation. As in case of the antebellum US, the elements of a unitary state, federation,

confederation, international and supranational organisation are creating too many

divergencies and they need to be addressed. Just like it happened in the US, where long-

4 For example, no other attempt of leaving the union was undertaken by any state.


standing process of power-negotiation between the states and the federal government

climaxed in the civil war. The EU’s climax is in my opinion taking place right now. Surely,

it does not mean, like it did not mean in the case of the US, that a solution will be adopted

and the “New EU” will be born. It will be longue durée that started years ago and will last

long after the climax will have passed – just like in the United States.

Federalists vs confederalists

The tendencies that I call here federal and confederal were present in the UE and the

EU from the very beginning. As I argue, they were to large extent responsible for the crisis

in both polities, and they are visible even today in the US, not to mention the EU. In the

United States, at the very beginning, they took the form of federalist vs anti-federalists5

dispute. This dispute was the result of poor performance of the US under the Articles of

Confederation, especially in economy . The federal government was most of all obliged to

guard the sovereignty and independence of the states, but could not even levy taxes to

repay the Revolutionary War debts. Moreover, it had no policing forces and no army to

implement effectively its decisions on one hand, and to defend the states from external,

or internal, threats (rebellions, colonial powers, native Americans etc) on the other hand.

Nevertheless, as the integration followed under the United States Constitution, the

conflict between federalists and confederalists evolved, but did not cease. The division

between Northerners living under commodified, industrialising market economy and

Southern farmers and planters, divided into strict class-based society, with the extensive

use of slavery, fit mostly into the dividing lines between unionist vs proponents of states’

rights. In spite of the cycles of centralisation and decentralisation fuelled by the Supreme

Court decisions6, the union was becoming more integrated. In the end, the failure of

Nullification Doctrine, made the southern states try more decisive actions, namely

secession.

Federalists and confederalists in the EU are divided into groups, often referred as

federalists/supranationalists vs intergovernmentalists. The essence of the dispute is

analogical as in the US. Federalists are proponents of a stronger integration and transfer

of power to the European institutions (expanding majority voting, a deeper integrated

5 The name „Anti-federalists” was given to them by the Federalists, and the former did not agree with it, as they argued that they are the real federalists. This fact could mean that at that time the Federalists were more effective in shaping the discourse and managed to pigeonhole confederalists as people who are against the federation, ergo unpatriotic (Maine, 2004: XXIII) 6 Vide: McCulloch v. Maryland (1819), Gibbons v. Ogden (1824), Nullification Crisis (1828-1832)


Eurozone, common army etc.), while intergovernmentalists would like to see the EU as

the Europe of Homelands, where the member states remain in full control over the

process of European integration7. The rationale behind progressing federalisation in the

EU is also similar to the one in the US: economic effectiveness and threats to the polity8.

This division can also be observed right now in the EU and constitutes, more or less, a

socio-economic-geographic cleavage. We have well developed, services-based economy

of the Western and Northern EU and less advanced, more industry and agriculture based

Eastern and Southern member state of the EU.

As in the US, the EU has adopted a constitution (not called by this name), the Lisbon

Treaty, to overcome the institutional shortcomings. And as in the US, this move produced

a backlash of “European antifederalists” – we can see serious attempts to “nullify” the

decisions of the European institutions on the national level9. And finally, as in the US, the

Court of Justice is the proponent of “creeping federalism” in the EU, following mostly the

rule of in dubio, pro integratione in its decisions (Bobek, 2014: 19).

In conclusions for this section, I would like to state that mutatis mutandis, especially in

terms of time, space and environments, the long-lasting mechanisms and processes in the

US and the EU are quite similar in the essence. Therefore, a process-tracing in these cases

can unravel how certain decision and episodes in the US can be translated into the

situation of the EU and its much shorter timeframe.

Conflict between inclusive and extractive political institutions

The conflict between inclusive/open access and extractive/limited access institutions

and orders is another dimensions of diverging tendencies and goes, in general, along the

division between federalists and confederalists. Both concepts deal with the problems of

the societies (nations) on the path to development, with the reservation that Acemoglu

and Robinson focus on their eponymous question “Why Nations Fail?”. Nevertheless I

think both frameworks will be useful in analysing American and European10 societies, as

7 The aim of the article is not to embroil into the discussion on labels, but in literature, the division here is named as between supra-national (more federal-like) and inter-national (more confederal) cooperation. 8 At the dawn of the European Communities: the internal threat were Communists and Germans, the external one was the Soviet Union. 9 For example relocation and resettlement of asylum seekers, where some member states, mostly Eastern, managed to “nullify” the decision of central institutions. 10 I will use the word „European” in reference to the society meaning EU citizens.


they have a potential to explain the great strives within them. Regardless of the fact that

citizens of the EU do not compose a community that can be called a “nation”.

As briefly described in the introduction to this paper about both conceptual

frameworks, institutions or orders can be divided into inclusive and open access on one

hand, and extractive and limited on the other. Instead of repeating main the assumptions

of these concepts, I will focus on the dynamic perspective of a socio-economic-political

change offered by them. In short, inclusive institutions are social regimes, where

numerous people are involved in the process of governing and can influence them and

benefit from them. Extractive institutions are based on the exploitation of many by few

and mobility upwards the social ladder is very hard (Acemoglu, Robinson, 2012: 316).

Open access orders guarantee the access to governing by the effectiveness of law,

safeguarded by state monopoly of violence (nested in law). Limited access orders are

controlled by the stronger: their dominance is safeguarded by the use of violence and the

law is subservient to the stronger’s interests (North, Wallis et. al., 2007: 2-3).

Almost intuitively, one could assign extractive/limited access institutions to the

antebellum South in the US, and to East-South members of the EU. I am convinced that

this generalisation is mostly justified, but it is still a generalisation. Surely, it is easy to

produce clear evidence that Southern US was extractive and with limited access for most

of its society, not only enslaved African Americans, but also masses of impoverished White

males (not to mention women and Native Americans). The system was elitist and

beneficial for few. The same descriptions fit into the reality of so called “new members” of

the EU” (10+2 [Bulgaria and Romania]+1 [Croatia]), with the obvious exclusion of

slavery11. Social mobility and respect for the rule of law is still much more problematic in

the East of the EU, than in the West. Authoritarian tendencies in Hungary, Poland and

Romania are lately the most apparent examples. In spite of these great divisions, it is

important to remember that extractive and limited access institutions are visible not only

in a vertical perspective, but also in the horizontal one. International financial markets

and transnational corporations are just one of the examples, one can think of, building on

Acemoglu’s and Robinson’s concept (Levine, 2012). One does not have to stress that the

11 Although, one could argue that serfdom in some territories of modern Poland was comparable to the slavery. It even ended formally about the same time, as slavery in the US, by the decree of Russian Czar (1867). Naturally, serfdom did not exist at the time when European integration started, nevertheless, the consequences of serfdom can be traced even today.


effects of exclusion and limited access in this case can be easily traced also in the West

and liberal, blue states of the US, not only in the US South and EU’s East.

What is the most important, however, in the context of my research, is that both

theories assume that, when these two orders meet within one polity, frictions appear.

These frictions appeared and evolved into a conflict in both 19th century US and modern

EU. As North, Wallis, Webband, Weingast describe, there are conditions under which

institutions and orders can transform, from limited access to open access. And even

though the cleavage still holds in the US (even today) and the EU, the transition is also

visible. The point is that this process is not continuous and uninterrupted – again, recent

political conflicts within the EU, and the history of postbellum US (and even today!) shows

that inclusive/open orders are in conflict with extractive/limited orders and clash with

each other.

Belief in own exceptionalism

To some extent, both polities, their leaders and societies, are convinced that they are

special, like no one other before – they see themselves as exceptional. The conviction of

own exceptionalism is mostly derived from the status of sui generis entities that both the

US and the EU. It induced the belief that because they are something new, the political

architecture they build is unique and can bring change to the world (Della Sella, 2010: 7).

Sui generis character is of course a facilitator of exceptionalism, but for both polities it

is the values that they adhere to that is the main source of exceptionalistic self-

identification. Personal and collective freedom, democracy, open-market economy, rule

of law, equality – these are the values that Americans and Europeans officially follow. Even

though in the US, the concept of American exceptionalism was early connected with the

religious fervour (the concept of “City upon a Hill”), both polities describe themselves as

Empire of Liberty (Thomas Jefferson) or “normative power” in case of the EU. Both of

these concepts, and concepts of exceptionalisms in general, are connected with “power”,

ergo influence. It points to the fact that they include inseparable elements of

expansionism (sometimes even messianism), directed at exercising influence on the

external world. In case of the US, it is expressed in the form of Manifest Destiny – American

19th century convictions that Americans have to expand in terms of spreading their benign


values to all the people12. In case of the EU, it is explicitly stated in its security strategy

that the EU’s aim to promote and expand the zone of stability, freedom, democracy and

wealth among neighbours of the EU and globally (Shared Vision, Common Action, 2016).

Of course the opinion that the American or EU’s exceptionalism is something positive

is not universally shared. Not so rarely its is associated with expansionism in the meaning

of imperialism and imposing own rules, not necessarily by force (more often associated

with American expansionism) but also by symbolic violence (associated with EU’s soft

power). Nevertheless, what is really unique about the EU and US is the fact that they are,

to some extent, recognized internationally. Mainly through the process of treating the EU

or the US as a reference point, positive or negative. The US is often regarded as the oldest

modern democracy in the world, or the peace guarantor (mostly by its allies). The EU, in

turn, serves as a blueprint for regional integration for such organisation like African Union

or ASEAN or as an object of aspirations, like in the case of Euromaidan in Ukraine in

2013/2014.

For the purposes of my research, the most important element is the internal dynamic

of these compound polities vis-à-vis the myth of exceptionalism. In both cases, it has been

used as a tool for forging unity between otherwise very different member states.

Exceptionalism is definitely one of the founding myths for these polities (Tonra, 2011;

Hodgson 2010).

Institutionalisation of integration oriented towards federalisation

Looking at the integration of the EU and the US from the historical perspective, one

could come to the conclusion that there is a clear tendency towards federalisation in both

cases, at least from the institutional perspective. While it may be true in the long-term

perspective, the process is more nuanced in each case. In the EU, even though the political

climate around transferring more and more powers to central institutions has been

changing throughout the years, the institutions have been redesigned slowly but steadily

towards a deeper integration13. The main rationale behind this was usually to boost

12 This explanation of American expansionism can be found also in modern US policy. One example being the justification of the American invasion on Iraq, when President G.W. Bush stated that it is US obligation to spread democracy: "CNN.Com – Bush Pledges To Spread Democracy - Jan 20, 2005". 2018. Edition.Cnn.Com. Accessed July 20 2018. http://edition.cnn.com/2005/ALLPOLITICS/01/20/bush.speech/. 13 The European Council can serve as the example. Created after a so called “empty chair crisis”, where Charles de Gaulle opposed growing supranationalisation of the European Communities and he wanted to retain national control over the process. These objections were incorporated into the institutional


effectiveness of the Union, as political leaders saw its shortcomings. In the US, in turn,

besides the swinging mood on deeper integration within the society and politicians, also

the very process of advancing institutional integration was uneven, with periods of

institutional centralisation, followed by decentralisation and again by another version of

centralisation. One of the most notable examples of such processes is the battle over the

central bank in the United States, which is a long-running epopee (“History of Central

Banking”, 2018)14.

Draft hypotheses about the institutional integration in the US and the EU mark another

difference in this process in both polities. The European integration was from the very

beginning, and is mostly until now, a top-down process, a design of political leaders

proposed to the society. The process of American integration (to use a parallel framing)

was at the very beginning essentially a bottom-up process, with vast groups of a politically

empowered society (white males) convinced that in order to reach their goals, some level

of integration is necessary. The difference between a top-down and bottom-up design is

absolutely essential, in my opinion, for the shape of both compound polities, but I will deal

with it in more detail in the following section. In terms of institutionalisation, however,

this hypothesis explains differences in cycles between the US and the EU. European

institutions go mostly one way, because they are path-dependent, dependent on the spill-

over process, based in decision of political elites, convinced of the necessity of deeper

integration (at least in the Western part, dominating the decision-making in the EU). In

the United States, the institutionalisation is more cyclical, because it depends to a greater

extent on the political mood among a much wider group of the decision makers – the

society. And even though the US is a fully-fledged federation that can enforce its decision

(even violently – Civil War), and the EU is a supranational polity having problems with

enforcing member states’ adherence to the basic rules of law, still it is the US system that

has more democratic legitimacy.

The conclusion here is that in the US (bottom-up design), citizens have more power

over institutions, including state’s institutions, and in the EU, institutions (including

state’s) have more power over citizens. EU citizen has fewer tools to defend themselves

against the abuse of institutional power. EU institutions work through states’ institutions,

architecture of the organisation in the form of the European Council. This helped to break the stalemate and continue with the process of integration. 14 With many banking systems, including the central bank, many national banks and federal reserve banks.


and in this process, they have no executive power to enforce their decisions. Ergo if a state

abuses its citizens, the effectiveness of EU central institutions comes from the will of the

political elite of a member state to comply. As there are no policing forces in the EU, the

only tool that is left is normative soft power (including economic pressure). A very good

exemplification of these problems currently is the conflict between Brussels and

governments in Warsaw and Budapest.

Process of identity creation

The process of American identity creation and European15 identity creation share one

diverge in our very important point: as in the case of institutionalisation, the identity

creation in the US was a bottom-process and in the EU it started rather as result of a top-

down design. Of course, one has to bear in mind that the European identity (understood

broader) than just the identity of EU’s citizens, is a much older, long-lasting and

patchworked process. Some of the most important elements that influenced the sense of

Europeanness are the legacy of the Roman Empire, Catholic Church or Enlightenment.

Nevertheless, my units of comparison here are clearly defined polities: a state, the United

States of America one hand, and a supranational organisation, the European Union. And

just as the European identity is grounded in a long-lasting process predeceasing the

creation of the EU, so the identities prior to the American (state/national) identity were

developing before the establishment of the US. Therefore, I focus on the identities existing

within these polities, not forgetting the longe durée of the process.

One very important difference between Americanness and Europeanness is that the

former is already a shaped identity, whereas the status of latter is still contested

(Zimmermann and Dür, 2012).16 Both identities are multilevel and nested, consisting of

the central (union) level and member states. These levels of identity are to a great extent

not exclusive – one can be a Californian and an American, a German and European at the

same time. Both identities can be described as a “patchwork” identities, created out of

many (Mendez, Bachtler, 2018) . On the other hand, the concepts of central identities are

officially defined differently on both sides of the Atlantic. The US motto is: E pluribus,

unum, “out of many, one”. The EU’s motto stands In variatate concordia – the official

translation is “united in diversity”, but I think that essence of the motto is better shown

15 Here, by „European” I mean identity of the EU’s citizens. 16 This difference in potentially beneficial for the comparison, because the American case can serve as a possible scenario for European identity development.


by “harmony in diversity”. The difference between these mottos conveys the difference

between both polities quite well. The American identity is more solidified, stronger and

more unitarian. Out of many elements, we come as one – emphasis is put more on unity.

In the EU in turn, the emphasis is on diversity – we retain our differences, but are

harmonious.

One last significant element that I would like to describe in this brief outline of the

identity issue is the question of legitimacy. Legitimacy, or rather lack of it, is one of the

most often pointed problems of the EU. The legitimacy of the EU among its citizens seems

to be conditional and depends on the material well-being of the citizens. The better the

economic situation, the more support for the EU among citizens. It is so, because the EU

has embraced a for-the-people (output) approach to the legitimacy (Schmidt, 2012). This

entails that leaders govern for the good of the people and in this situation, as long as they

are effective in it, they are legitimised. This model of legitimacy comes directly from the

elitist, top-down design of the EU. It evolved over time (see a [slowly] growing position of

the European Parliament), but still maintains its original traits. In the US, in turn, the

dominant type of legitimacy is by-the-people. Here citizens are responsible for the process

of governing, are greatly involved in the process of decision making and do not condition

their support for the whole system only on the positive outcomes of leaders’ rules. The

effects of the for-the-people and by-the-people approach to governing and legitimacy is

that the latter proves to be more stable. A polity with this approach seems to be more

resistant to different crises, as the citizens remain loyal and engaged not only through

thick, but also through thin.

Influence of external environment

A comparison of the influence and pressure from the external/international

environment in the antebellum US and the EU bears the traits of similarity and difference.

Both communities were formed under strong pressure of a common enemy, or even

enemies. In the US, the pressure was more open and direct and had the form of the

Revolutionary War against the British Empire. The EU was strongly influenced by the fear

of a possible reinstallation of German power and the threat from Soviet Union. It is worth

noticing that though in both cases the threat was mostly external, at the same time it

brought some internal threats: British Empire still had support of a significant group of

loyalists in rebelling colonies (Calhoon, 2000) and communists had a lot of supporters in

France and Italy after the II World War (Greene, 1968). One could also argue that both


polities at their beginnings had a protector, who was looking for an opportunity to weaken

its global enemy. In American case, it was France (Schiff, 2006), trying to undermine the

colonial power of British Empire. In the EU it was US, aiming at rebuilding Western

Europe, destroyed and atomised after the horrors of past war, to acquire a reliable partner

in the confrontation against USSR. In a way, both protectors were facilitating cooperation

within the compound polities at the initial stage, giving a primary impetus for future

integration.

The most important difference between both cases is, in my opinion, the effect of

globalisation. I do not mean the mythical and blurry concept of globalisation, but the

question of a much deeper global interdependence in the times of the European Union.

The internationalisation of trade in 19th century was indeed close to the internalisation of

trade today, but mostly in terms of volume. The qualitative difference between “19th

century globalisation” and “modern globalisation” is the information age17. Therefore, I

draw a conclusion that in the case of the EU, which is much more interconnected, the

external environment since the very beginning has played a much more important role.

At the same time, in spite of different eras and Zeitgeist in international relations, both

sui generis polities shared and still share their belief about their historical mission – to

spread the values they are based on. As it was already said before, from their

exceptionalism stems a messianic approach and expansionism. Both polities share this

trait and it is visible in their foreign relations, in how they approach third parties and how

they approach each other. I would argue that the territorial development of both polities

was marked by a growing expansionism of both, mutatis mutandis, with weaker or

stronger opposition from competing powers – colonial powers (British Empire, France,

Spain) in case of US or Soviet Union/Russian Federation in the case of the EU. And last,

but not least, even today, in spite of historically cold transatlantic relations, most of the

decision makers and societies share the conviction, that the EU and the US should

cooperate (“Enthusiasm for NATO far lower in US than in Europe”, 2018) for the sake of

international security, based, of course, on the values of freedom and democracy.

17 It is absolutely beyond the scope of this article to debate the concept of globalisation, therefore I limit myself to basic claims.


Conclusion

A brief description and analysis of processes and tendencies within the US and EU

compound polities show that they faced similar issues and problems, among others:

power bargain between the centre and constituents, political identity building,

integration through law. Of course both entities display significant differences, like

Zeitgeist (international environment), different political structure (US had a national

party system almost from the very beginning, the EU does not have truly supranational

parties even today). The most important difference, nevertheless, is the bottom-up vs top-

down design. This difference has the most far-reaching consequences for both polities.

The bottom-up design in the case of the US resulted in a stronger and deeper process of

creation of political agora and state identity. This, in turn, results in a by-the-people

legitimacy which, as I argue, led to the US integration following the path of a more perfect

union, as the Americans identify themselves not only with their states but also their

federation. Meanwhile, the legitimacy-for-the-people in the EU does not steadily involve

the citizens in the project of an even closer union. Their loyalty is conditional, depends on

the effectiveness of the supranational institutions and fluctuates constantly.

Using the paradigm of social constructivism, the question of bottom-up design in the

US and top-down design in the case of the EU presents itself as the single most important

research problem within my research project. It is very important, however, to

understand some limitations and possible pitfalls of this approach. Reductionism is one

of them – focusing too much on one issue can lead to explaining all process with this one

reason. Units of analysis make it a research from a macro perspective, focusing on

complex compound polities, omitting, to a large extent, the characteristics and differences

between member states. Furthermore, I conduct an ahistorical comparison, so it is

especially important to contextualise every phenomenon. In this kind of research, there

is also an always-present danger of ignoring contingency randomness, for example

election’s results that may lead to a completely different course of history.

All these risks are the price for the scope of the research and the method of process-

tracing (combined with an analytical path-dependency). Nevertheless, I am still convinced

that the results may constitute a new perspective on the process of European integration

and show that some political processes are not entirely unique and can be, to some extent

at least, designed and influenced.



Bibliography

Acemoglu D., Robinson J.A., Why Nations Fail, Crown Publishing Group 2012.

Adler E., Pouliot V., “Introduction and Framework” in: “International Practices”, Emanuel Adler

(ed.) and Vincent Pouliot (ed.), Cambridge University Press 2011.

Banks Ch.P., Blakeman J.C., The U.S. Supreme Court and New Federalism: From the Rehnquist to the

Roberts Court, Rowman & Littlefield Publishers 2012.

Barnett M., “Social Constructivism” in: The globalization of world politics: an introduction to

international relations, John Baylis, Steve Smith , Patricia Owens (eds), Oxford University Press

2016.

Beach D., "Process-Tracing Methods In Social Science" in: Oxford Research Encyclopedia Of

Politics. Oxford University Press 2017, http://politics.oxfordre.com/ (24.11.2017).

Beeman R. (eds) et al, Beyond Confederation: Origins of the Constitution and American National

Identity, University of North Carolina Press 1987.

Bobek M., The Court of Justice of the European Union, Research Paper in Law 02/2014,

Boşilcă R. L., “The European Union - A ‘Sui Generis’ International Diplomatic Actor: Challenges Posed to the International Diplomatic Law Romanian”, Journal of European Affairs, 2014, 1: 22-

33.

Bourdieu P., Distinction: a Social Critique of the Judgement of Taste, Cambridge, Harvard University

Press 1984.

Bryant A., "Re-grounding grounded theory", Journal of Information Technology Theory and

Application, 2002, 4: 25–42.

Burgess M., Federalism and the European Union: The Building of Europe, 1950-2000, Routledge

2000.

Calhoon R.M., “Loyalism and neutrality”, in A Companion to the American Revolution by Jack P.

Greene and J. R. Pole (eds.), Blackwell Publishers 2000.

Ceruti F., Lucarelli S., The Search for a European Identity: Values, Policies and Legitimacy of the

European Union, Routledge 2011.

Checkel J.T., Katzenstein P.J. (eds.), European Identity, Cambridge University Press 2009

Del Sarto R.A, "Normative Empire Europe: The European Union, Its Borderlands, And The ‘Arab

Spring’", Journal Of Common Market Studies, 2014, 54 (2): 215-232.

Della Sella V., “Political Myth, Mythology and the European Union”, Journal of Common Market

Studies 2010 Volume 48, Number 1, pp. 1–19

Drake F.D., Nelson L., States' Rights and American Federalism: A Documentary History, Greenwood

1999.

Enthusiasm For NATO Far Lower In US Than In Europe, 2018,Today.Yougov.Com. Accessed July 24

2018. https://today.yougov.com/topics/international/articles reports/2017/01/26/nato-

enthusiasm-lower-us-europe-americans-dont-agr.


Fabbrini, S., Compound Democracies: Why the United States and Europe Are Becoming Similar,

Oxford University Press 2009.

Faust D.G., The Creation of Confederate Nationalism: Ideology and Identity in the Civil War South,

Louisiana State University Press 1990.

Feeley M., Rubin E., Federalism: Political Identity and Tragic Compromise, University of Michigan

Press 2011.

Freehling W.W., The Reintegration of American History: Slavery and the Civil War, Oxford

University Press 1994.

Friedman R., Thiel M., European Identity and Culture: Narratives of Transnational Belonging,

Ashgate Publishing 2012.

Giddens A., The Constitution of Society Outline of the Theory of Structuration, University of

California Press 1984.

Glencross A., What Makes the EU Viable? European Integration in the Light of the Antebellum US

Experience, Palgrave Macmillan 2009.

Gould A.C., Messina A.M. (eds), Europe's Contending Identities: Supranationalism,

Ethnoregionalism, Religion, and New Nationalism, Cambridge University Press 2014.

Greene T.H., “The Communist Parties of Italy and France: A Study in Comparative Communism”,

World Politics Vol. 21, No. 1 (Oct., 1968), pp. 1-38.

Halberstam D., Reimann M., Federalism and Legal Unification: A Comparative Empirical

Investigation of Twenty Systems, Springer 2013.

Heiss-Morse E., Who Counts as an American? The Boundaries of National Identity, Cambridge


History of Central Banking From 1791 to the 21st Century,

https://www.philadelphiafed.org/education/teachers/resources/history-of-central-

banking/ (21.07.2018)

Hodgson G., The Myth of American Exceptionalism, Yale University Press 2009

Jackson P.T., Nexon D.H., “Relations Before States: Substance, Process and the Study of World

Politics”, European Journal of International Relations, 1999, 5 (3): 291–332.

Jonsson Ch., Tagil S., Tornqvist G., Organizing European Space, SAGE Publications 2000.

Kagan R., Of Paradise and Power: America and Europe in the New World Order, Alfred A. Knopf

2003.

Kaminski J.P., Leffler R., Federalists and Antifederalists: The Debate Over the Ratification of the

Constitution, Rowman & Littlefield Publishers 1998.

Karmis D., Norman W., Theories of Federalism: A Reader, Palgrave Macmillan 2005.

Keulman K., Koos A.K., European Identity: Its Feasibility and Desirability, Lexington Books 2014.

Koslowski R., Kratochwil F., “Understanding Change in International Politics: The Soviet Empire’s

Demise and the International System”, International Organization, 1994, 48 (2): 215–47.

LaCroix A.L., The Ideological Origins of American Federalism, Harvard University Press 2011.


Lacroix J., “For a European Constitutional Patriotism”, Political Studies, 2002 50 (5): 944–58.

Leder A., Prześniona rewolucja: ćwiczenia z logiki historycznej, Wydawnictwo Krytyki Politycznej

2014.

Main J.T., The Antifederalists: Critics of the Constitution, 1781-1788, UNC Press Books 2004

McCourt D.M., "Practice Theory And Relationalism As The New Constructivism", International

Studies Quarterly, 2016, 60 (3): 475-485.

McGuire S., Smith M., The European Union and the United States: Convergence and Competition in

the Global Arena, Palgrave Macmillan 2008.

McNamara K.R., “Constructing Authority in the European Union” in: Deborah Avant, Martha

Finnemore and Susan Sell (eds), Who Governs the Globe? Cambridge University Press 2010.

McNamara K.R., Imagining Europe: Symbols, Practice and Banal Authority in the European Union,

Oxford University Press 2015.

Mendez C. and J. Bachtler, European Identity and Citizen Attitudes to Cohesion Policy: What do we

know? COHESIFY RESEARCH PAPER 1 COHESIFY WORK PACKAGE 2 - TASK2.1: OUTPUT 2

2018

Morgan G., The Idea of a European Superstate: Public Justification and European Integration,

Princeton University Press 2005

Norman W., Negotiating Nationalism: Nation-Building, Federalism, and Secession in the

Multinational State, Oxford University Press 2006.

North D.C, Wallis J.J, Webb S.B., Weingast B.R., Limited Access Orders in the Developing World : A

New Approach to the Problems of Development. Policy Research Working Paper; No. 4359.

World Bank, Washington, DC 2007.

Ortner S., Anthropology and Social Theory: Culture, Power, and the Acting Subject, Duke University

Press 2006.

Reid T., The United States of Europe: The New Superpower and the End of American Supremacy,

Penguin Books 2005.

Risse T., A Community of Europeans? Transnational Identities and Public Spheres, Cornell


Sbragia A., “The United States and the European Union: Comparing two Sui Generis Systems” in:

Comparative federalism: the European Union and the United States in comparative perspective,

Anand Menon and Martin Schain, Oxford University Press 2006.

Schmidt V.A., “Democracy and Legitimacy in the European Union”, in The Oxford Handbook of the

European Union by Erik Jones, Anand Menon, Stephen Weatheril (eds.), Oxford University

Press, 2014.

Schatz B., How to Establish a Corporate Identity for the European Union: Development of a Brand

Concept to create an "us-feeling" amongst European Citizens, AV Akademikerverlag 2014.

Schatzki T., Knorr K., von Savigny E., The Practice Turn in Contemporary Theory, Routledge 2001.

Schiff S., A Great Improvisation: Franklin, France, and the Birth of America Henry Holt and Company,

Holt Paperbacks 2006.


Smith-Rosenberg C., This Violent Empire: The Birth of an American National Identity, University of

North Carolina Press 2010.

Stepan A.,”Federalism and Democracy: Beyond the U.S. Model”, Journal of Democracy, 199, 10

(4):19–34.

Tilly C., Big Structures, Large Processes, Huge Comparisons, Russell Sage Foundation 1984.

Tonra B., “Democratic foundations of EU foreign policy: narratives and the myth of EU

exceptionalism”, Journal of European Public Policy Volume 18, 2011

Trechsel A.H., “How to Federalize European Union… and Why Bother?”, Journal of European Public

Policy, 2005, 12: 401-18.

Trubek D., Bourgoignie T. (eds), Consumer Law, Common Markets and Federalism in Europe and

the United States, De Gruyter-Recht 2013.

Wendt A., Social Theory of International Politics, Cambridge University Press 1999.

Wæver O., “Europe’s Three Empires: A Watsonian Interpretation of Post-Wall European

Security”,in: Rick Fawn and J Larkins (eds), International Society after the Cold War, Macmillan

1996.

Why Do Nations Fail, HuffPost, 2012. Web. 20 July 2018.

Zimmerman J.F., Contemporary American Federalism: The Growth of National Power, State

University of New York Press 2009.

Zimmermann H., and A. Dür (eds.), Key Controversies in European Integration. The European Union

Series. Basingstoke, Palgrave Macmillan, 2012, pp. 103-111.

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Pax Americana meets Pax Europaea. Comparative study of … · 2018-08-20 · Karol Chwedczuk-Szulc, University of Wrocław, Poland Pax Americana meets Pax Europaea. Comparative study