Comparative Analysis of the US Presidential System and the Canadian Parliamentary System

For years, political scholars have studied two types of democratic governmental

systems, presidential systems and parliamentary systems, and analysed them as to their

effectiveness and the ability of each system to uphold democratic principles. This essay will

add to this discussion by comparing Canada’s traditional Westminster parliamentary system

and the United States’ prominent presidential system. These two countries were chosen due

to their close cultural ties, similar plurality electoral system, and somewhat similar political

orientation. Since the countries have a lot in common, it will allow me to focus specifically

on the effects of the governmental system on the two countries. This paper will analyze the

strength and weaknesses of both systems, and will argue that the Canadian parliamentary

system functions as a more effective and desirable governmental system.

In order to argue that parliamentary systems are more effective then Presidential

systems, this paper will explain the differences between the two systems, which I feel prove

that the Canadian system allows for a stable, accountable, and an efficient government. The

paper begins with a theoretical analysis, where I will explain the views of the main political

scholars who have tackled this question. The paper will then focus on the structure of the

bureaucracy in the two systems, and explain how the American separation of powers system,

creates a complex, an ineffectual system, compared to the Canadian government that has less

restrictions, and allows for effective policy making. I then go into explaining the specific

difference between responsible government (Canadian system) and separation of powers

(American system). Through explaining the difference between the two organizations I will

prove that the responsible government system creates cohesion between the different levels of

government, which I will argue allows for a more efficient and effective policy making

structure. Lastly the paper will analyze electoral policy and its impact on party discipline and

1
party strength. Through this analysis I will prove that the Canadian system allows for

increased party discipline, which leads to strong and cohesive parties.

Brief Theoretical Analysis

There is an ongoing debate between political researchers on the institutional

consequences of presidential and parliamentary systems. Political researchers such as Juan

Linz, Arend Lijphart, Stephan Haggard, and Matthew McCubbins, have argued that

parliamentary systems are more effective, and that they lead to a more stable democracy.1 But

there are many political scholars, for example Matthew Shugart, Scott Mainwaring, Bradford

Wilson, and Peter Schramm who disagree and have argued for the superiority of the

presidential system.2 Despite the fact that this debate has been going on for decades, there is

no consensus of which system is better. In order to present my own opinion I feel it is first

important to understand the theory behind the debate. Lijphart outlines three main differences

between presidential and parliamentary systems: a) in parliamentary systems the head of

government requires the confidence of the legislature in order to stay in power, while in a

presidential system the President remains in power for a fixed period of time (four years); b)

in a presidential system, the electorate votes directly for the President, while in a

parliamentary system leaders are selected by the party; and c) in a parliamentary system the

Prime Minister as well as his cabinet make up the executive, in a presidential system, the

President alone is a one-person executive.3 Another difference which Lijphart partly touched

on is that in the presidential system each level of government is separate, a phenomenon

1
Main sources I used that argue for Parliamentary systems: Juan Linz, “The Perils of Presidentialism”, Journal
of Democracy (1990), pp. 51-69, p. 51; Juan Linz, “The Virtues of Parliamentarism” Journal of Democracy 1, 4
(Fall 1990): 85-91. Arend Lijphart, “Consociational Democracy” World Politics 21, 2 (1969), pp. 207-225;
Stephan Haggard, and Matthew McCubbins, Presidents, Parliaments, and Policy, (Cambridge, Cambridge
University Press, 2001);
2
Scott Mainwaring and Matthew S. Shugart, “Juan Linz, Presidentialism, and Democracy A Critical Appraisal,”
Comparative Politics 29 (1997): 449-471.
3
Arend Liphart, Parliamentary Versus Presidential Government, (Oxford, Oxford University Press, 1992), pp.
2-3

2
known as “separation of powers”. This phenomenon is created by the existence of separate

elections for the President and the Congress.4 In Canada the Prime Minister is simply an MP

(Member of Parliament) who is named the leader of the party; yielding a situation in which

there is no separation of powers.

With the understanding of the essential differences between the two systems, we can

now look at the arguments for both systems. The general consensus of scholars who support

parliamentary systems is that compared to a presidential system, there is a more centralized

decision making process, parties tend to be stronger, and the government leader is more

responsible to the legislature and ultimately more accountable to the citizens.5 Scholars who

support presidential systems argue, that separation of powers allows for a strong legislature,

voting directly for the President confers greater transparency, the system encourages

pluralism (which allows for a diversity of views to be expressed), and that proposed bills are

scrutinized and voted on by two levels of government, which some argue increases the

accountability of the system.6 The arguments for each system are strong, but in many ways

it’s the arguments against the systems that are most important. Shugart and Mainwaring have

argued that in the Parliamentary system there can be a relative lack of scrutiny in passing

some bills, making passage to easy. 7 Another criticism of parliamentary systems has been

voiced by Moe and Caldwell. They explained that due to the power of the Prime Minister it is

harder to form compromises between the parties and interest groups. They further go on to

say that in many parliamentary systems laws can get overturned when the opposition party

4
Alan Siaroff, “Comparative presidencies: The inadequacy of the presidential, semi-presidential and
parliamentary distinction”, European Journal of Political Science 42 (2003), pp. 287-312, p. 288
5
General understanding of the advantages after reading the different articles on the subject, as well as
information from class discussion
6
General understanding of the advantages after reading the different articles on the subject as well as
information from class discussion
7
Michael Mezey, “New Perspectives on Parliamentary Systems: A Review Article”,
Legislative Studies Quarterly 19 (1994), PP. 429-441, P.430

3
wins an election, resulting in instability in the system.8 Some have even said that

parliamentary systems are not truly democratic because citizens don’t vote directly for the

leader of the nation, but instead they can only vote for their member of parliament. Similarly,

there are also a substantial number of arguments against presidential systems. The most cited

criticism is that the presidential system may create a major split between the executive and

the legislature, which may make the law making process futile.9 This leads to another

problem with Presidential systems, which is that they tend to be not as stable as

Parliamentary systems, due to the constant debate between different levels of government. 10

All of these issues will be expanded on throughout the paper, in order to prove that

Parliamentary systems are in fact the better of the two systems.

Bureaucracy and the effectiveness of policy making

When choosing between parliamentary and presidential systems, one has to

understand that each system comes with its own consequences. As Moe and Caldwell explain,

“When nations choose a presidential or parliamentary form, they are choosing a whole

system, whose various properties arise endogenously whether they like it or not.”11 One of

the main institutional consequences of both systems is the size and effectiveness of the

bureaucracy. The American system, with its principle of separation of powers, has three

levels of government, the executive, the legislature, and the judiciary which are divided and

seen as equal.12 A “separation of powers” system will tend to create a large and divided

8
Terry M. Moe and Michael Caldwell, “The Institutional Foundations of Democratic Government: A
comparison of Presidential and Parliamentary Systems”, Journal of Institutional and Theoretical Economics 150
(1994), pp. 171-195, pp. 179
9
Juan Linz, “The Virtues of Parliamentarism” Journal of Democracy 1 (1990), pp.85-91, p. 89-90
10
Ibid.
11
M. Moe and Michael Caldwell, “The Institutional Foundations of Democratic Government: A comparison of
Presidential and Parliamentary Systems”, Journal of Institutional and Theoretical Economics 150 (1994), pp.
171-195, pp. 172
12
Juan Linz, “The Virtues of Parliamentarism” Journal of Democracy 1 (1990), pp.85-91, p.85

4
bureaucracy, with many formal restrictions creating an ineffective system.13 In part, this is a

result of essential differences between what a President and what the legislature would

consider “an ideal bureaucracy”. The legislature who needs the support of interest groups

would rather have an ineffective system, one buried in formal restrictions, because they rather

only pass bills that are truly supported by the majority of the population.14 Presidents on the

other hand would prefer an effective bureaucracy that allows for quick policy making.15

Unfortunately for the President, the legislature has set up the bureaucracy. As one can see this

creates a complicated relationship, one wherein a tight bureaucracy as set up by the

legislature can result in a slow and ineffective policy making process, essentially causing

internal strife between the President and the legislature. The parliamentary system does not

have this problem, mainly because the Prime Minister is part of the legislature. The simple

Westminster parliamentary system usually creates majority governments, where the Prime

Minister can easily pass a bill quickly and effectively, as he/she can rely on his/her party

members to vote for it.16 The parliamentary system allows the leader to have the type of

bureaucracy he/she wants, which is a system that allows him to pass his party’s policies and

focus on certain issues.17 It would be my view that having a smaller bureaucracy that allows

for quick and effective policy making is essentially better, than a system that can result in

internal strife between the different levels of government.

Another point that already has been briefly mentioned but requires amplification is the

issue of the power of the leader. The separation of powers system is set up mainly to place

checks and balances on the power of the leader, resulting in Congress and Senate having a

13
M. Moe and Michael Caldwell, “The Institutional Foundations of Democratic Government: A comparison of
Presidential and Parliamentary Systems”, Journal of Institutional and Theoretical Economics 150 (1994), pp.
171-195, pp. 175
14
Ibid.
15
Ibid. 175-176
16
Ibid. 177
17
Ibid.

5
considerable amount of power.18 In Canada, the Prime Minister has a lot more power vested

in the position, because he is ostensibly a part of the legislature. Given a majority of seats, the

government can easily pass bills through the House.19 It would be my view that the essential

advantage of the efficiency of passing policies outweighs the value of augmented scrutiny.

Responsible government vs. Separation of Powers

The Canadian parliamentary system is closely linked to the British system; both share

the concept of responsible government. Canada’s government can be divided three essential

components: a) the executive, made up of the Governor General (who represents the Queen),

the Prime Minister, and the Cabinet; b) The legislature, which is made up of the Senate and

the House of Commons; and c) the judiciary which is made up of the various courts

culminating in the Supreme Court.20 The notion of an “essentially responsible government”

can be understood as the idea wherein the executive is responsible for its actions to an elected

legislature.21 In Canada responsible government means that the Queen who is at the top

according to the constitution is responsible for the system as a whole. The Prime Minister is

the next level he is responsible to the Queen and to the legislature. The legislature is then

responsible to the President and the people that elect them. And the judiciary is responsible to

the legislature to enforce laws, and is responsible to the crown.22 “Responsible government”

can be viewed as the harmonious relationship between the executive and the legislature. The

executive is accountable to and owes its continued existence to the legislature. Indeed,

parliament can be prorogued or dissolved if the Prime Minister loses the confidence of the

18
Arend Liphart, Parliamentary Versus Presidential Government, (Oxford, Oxford University Press, 1992), pp.
15
19
Ibid. 31
20
The Canadian Constitution 1867 from sections 1-57 lay out the structure of the Canadian system including the
powers of each level of government
21
Canadian Study of Parliament Group, “Responsible Government”, October 1989, <
http://www.studyparliament.ca/English/pdf/ongoing/1989_10_E.pdf> retrieved February 7, 2012
22
Ibid.

6
House.23 The legislature is also responsible to the people, and if the public perceives that

government is not “doing its job” they will not get re-elected. Responsible government has

many advantages and allows for each level of government to be accountable to each other;

ultimately being accountable to the citizens.24 Another important feature of the Canadian

system is the intrinsic connection between the executive and the legislature as manifested by

the fact that the Prime Minister is an elected member of parliament, he/she sits in the House,

and plays an essential role in the decision making process.

Similar to Canada, the American system is tripartite having the executive (President),

the legislature made up of Senate and Congress, and the judiciary. As Lijphart has

commented, a major difference between the two systems is in the U.S., the executive is a one

person executive made up of just the President. Ostensibly the U.S. has the equivalent in that

has a cabinet population by the various secretaries (health, education, defence, etc.), but

constitutionally they are not part of the executive.25 This yields a disadvantage especially in

the situations of having to make critical or tough decisions.

The parliamentary system has the Prime Minister but also has the Cabinet. The

Cabinet is made up of Ministers who are Members of Parliament appointed to important

positions, and are in charge of certain jurisdictions.26 Each Minister is assigned its

jurisdiction by the Prime Minister. For example John Baird is the Minister of Foreign Affairs.

Having a Cabinet allows the executive to cover more issues, it allows the Prime Minister to

23
Ibid. (I also have a very good understanding of Responsible government, I have written an essay in fourth
year undergrad about responsible government and it’s significance to Canadian politics
24
Christine Leuprecht and Peter Russell, Essential Readings in Canadian Constitutional Politics, (Toronto,
University of Toronto Press, 2011), pp. 39
25
Arend Liphart, Parliamentary Versus Presidential Government, (Oxford, Oxford University Press, 1992),
pp.2
26
Privy Council Office, “About Cabinet”, http://www.pco-
bcp.gc.ca/index.asp?lang=eng&page=information&sub=cabinet&doc=about-apropos_e.htm, retrieved February
8, 2013

7
focus on pressing matters because he knows that his Cabinet Ministers will keep track of the

different policy areas.

Another big difference is the power of the legislature. Both the U.S. and Canada have

a House of Commons/Representatives and a Senate, but the Senate is quite different in the

American presidential system. In fact, the Canadian Senate and the American Senate are

similar in name only. The Canadian Senate is not an overly powerful body, and has become

so over the years mainly because Senators are appointed rather then elected, this mirroring

the British House of Lords.27 Indeed, there have long been calls in Canada for abolition of the

Senate, or the need for major Senate reform. As it stands now, the Senate, which is meant to

be a body for “sober second thought” functionally, cannot vote against most government

policies.

The American Senate is elected and for this reason has more power. The Senate has

the ability to vote on bills and in fact a bill must have the support of 60% of Senate in order

to move to the Congress to be voted on.28 This is quite a high threshold and there have been

many examples where bills enter but don’t leave the senate. The advantage of having a

powerful senate is that it keeps the congress and the President in check, and as explained

earlier adds to the bureaucratic structure that only allows for greater scrutiny of bills.29 The

disadvantage of the American senate is that it increases the time it takes to pass a bill and in

some cases prevents the President from passing policies that he promised he would enact.30

The biggest difference between the two systems is the simple fact that in the

American system the executive, the legislature, and the judiciary are all separate, each level is

27
Maple Leaf Web, “The Canadian Senate: Role, Powers, Operation”, <
http://www.mapleleafweb.com/features/canadian-senate-role-powers-operation>, retrieved February 8, 2013
28
Gregory Koger., “The Rise of the 60-Vote Senate,” Extensions, Winter 2012, pp.1-7, p. 1
http://www.ou.edu/carlalbertcenter/extensions/winter2012/Koger.pdf, retrieved February 8, 2013
29
Ibid. 4
30
Ibid. 2

8
designed to balance each other, in what is known as a system of checks and balances.31 In the

event of one is becoming too powerful there is a veto system.32 In the American system, in

order for a bill to pass it has to be signed off by the President and at that stage the President

has the ability to veto the bill.33 But the Congress can overturn the President’s veto with a

two-thirds vote in the Congress.34 The President also has the power to pass a bill through

what is known as executive order. Executive order allows the President to pass a bill even if

the legislature has already voted against it.35 For example Obama has threatened to use

executive order on gun control bills if the congress does not pass new regulations he is

currently proposing.36 The advantage of executive order is it checks the power of the

Congress, and allows the President to pass certain policies that he feels are important. The

disadvantage of executive order is the view that it gives the President too much, and an

overuse of executive order it can lead to an autocracy rather then a democracy. In contrast,

The Prime Minister does not have this power. In a majority government the Prime Minister

really does not need to have executive order because in most cases the bills he wants will be

passed.37 Personally I feel that responsible government is a more effective and stable system.

Its increased cohesion between the levels of government allows for effective policy making,

as well as increased accountability. The American system does have some strengths such as

31
Arend Liphart, Parliamentary Versus Presidential Government, (Oxford, Oxford University Press, 1992),
pp.15
32
M. Moe and Michael Caldwell, “The Institutional Foundations of Democratic Government: A comparison of
Presidential and Parliamentary Systems”, Journal of Institutional and Theoretical Economics 150 (1994), pp.
171-195, pp. 175
33
Nicole Slezac, “The Presidential Veto: A Strategic Asset”, <
http://www.thepresidency.org/storage/documents/Vater/Slezak.pdf>, retrieved February 8, 2013
34
Ibid.
35
Morton Rosenberg, “Beyond the Limits of Executive Power: Presidential Control of Agency Rulemaking
under Executive Order”, Michigan Law Review 80 (1981), pp. 193-247, p. 194
36
Anjali Sareen, “GOP Rep. Threatens Impeachment Over Obama’s Possible Executive Order On Gun Control”,
January 14, 2013, http://www.mediaite.com/online/gop-rep-threatens-impeachment-over-obamas-possible-
executive-order-on-gun-control/, received February 9, 2013
37
Jay Marenko, “The Prime Minister and President in Cabinet”, Maple Leaf Web, <
http://www.mapleleafweb.com/features/prime-minister-cabinet-canada>, retrieved February 9, 2012

9
increased scrutiny on bills, but separating the powers creates internal instability, and a system

which is quite ineffective at policy making.

Elections and Party Discipline

Another important difference between presidential and parliamentary systems is

electoral policy. In the American presidential system, the electorate ostensibly votes for three

individuals, their Senator, their Representative and their President.38 In addition to this

allowing for the separation of powers, supporters of presidential systems have also argued

that it is more democratic since the citizens are able to directly select both the leader and the

legislature.39 However, supporters of parliamentary systems have argued that it creates a

problem where a popular candidate might be selected rather then the one best for the job. As

a side note, the U.S. House of Representatives is elected every two years, further allowing for

the separation of the leader and the Congress.

One issue that can be construed as both strength and a weakness of the American

system, and is in sharp contrast to the Canadian system, is the possibility of having different

political parties “in charge” of different entities.40 For example, in the U.S., currently the

Senate has a majority of Democrats, the House of Representative has a majority of

Republicans and President Obama is a Democrat. There have been innumerable examples,

even in the last few years, since 2010, where the system has been extremely inefficient, with

the Congress repeatedly blocking certain social and economic policies that the President has

wanted to pass. This is arguably the most significant flaw of the separation of powers system,

if neither the executive nor the legislature are willing to compromise, nothing will get done.

38
“Presidential Election Laws: The Constitution”, http://www.archives.gov/federal-register/electoral-
college/provisions.html, retrieved February 9, 2013
39
Scott Mainwaring and Matthew S. Shugart, “Juan Linz, Presidentialism, and Democracy A Critical Appraisal,”
Comparative Politics 29, 4 (July 1997), pp. 449-471, p. 453
40
Juan Linz, “The Perils of Presidentialism”, Journal of Democracy (1990), pp. 51-69, 53

10
 The Canadian system is immune from the aforementioned problem because the Prime

Minister is not directly elected; instead voters elect a member of parliament in each riding.

The party, who wins the most seats, will then become the leading party, and their leader

becomes the Prime Minister, essentially making him/her a part of the legislature.41 This

system is not perfect and many have argued that it is undemocratic to not have a direct vote

for the leader. Although this may be true it would be my view that the efficiency and

productivity gleaned by this trade-off proffer a fundamental advantage to the Canadian

system.

The essential difference in the American and Canadian systems is also reflected in the

issue of party discipline. Party discipline simply means the ability of a party to influence its

members to support the party leader.42 Canada’s parliamentary system has a strong party

discipline. This is a by-product of a responsible government system, which was in part

created in support of strong parties. In this system, members of parliament have to vote with

their party in order to prevent the Prime Minister from losing the confidence of the House.

Party discipline is needed because the opposing parties increasingly scrutinize and often vote

against the government’s policies.43 This creates an imperative for any party in leadership

that in order for them to be effective; they have to have a unified vision, and strong support

for their leader.44 The electoral system also creates a strong party structure because the

electorate often vote for the “party” rather then for the leader of the party. In the Canadian

system as well as other parliamentary systems, the party’s manifesto is extremely important,

as in many instances citizens vote in support of a particular party’s suite of policies, with the

knowledge that their MP will tend to support the party manifesto if they get elected. Party
41
James R. Robertson, “The Canadian Electoral System”, Government of Canada, September 15, 2008, <
http://www.parl.gc.ca/Content/LOP/ResearchPublications/bp437-e.htm>, retrieved February 10, 2013
42
Keith Krehbiel, “Party Discipline and Measures of Partisanship”, American Journal of Political Science 44
(2000), pp. 212-227, p. 212
43
Jonathon Lemco, “The Fusion of Powers, Party Discipline, and The Canadian Parliament: A Critical
Assessment”, Presidential Studies Quarterly 18 (1998), pp. 283-302, p. 283-284
44
Ibid.

11
leaders and party members tend to put the party in front of their own personal views,

allowing for optimal policy making.45

The American presidential system sometimes creates party splits and thus weak party

discipline. This notwithstanding, for the most part, especially in the current system the

Democrats and Republicans do have strong party discipline. Indeed, the two parties have

become increasingly polarized on many issues and fundamentally hostile towards each other.

This has resulted in both parties having increased their party discipline. However, in the

American system party discipline is less important since there are separate elections between

the President and the legislature. Even if the parties are totally loyal to the President in order

for the system to be somewhat effective the parties have to compromise with each other.46

Although compromise is an important part of democratic governance, as parties increasingly

compromise with the attendant need to “make deals” with each other, there is a risk that they

will stray from the core of their party’s manifesto.

Conclusion

Most political scholars have attempted to answer the question: Which democratic

government system is better, Presidential systems or Parliamentary systems. So far there has

been no consensus; there are strong arguments for both systems. In this essay I did my best to

answer this question, through a comparative analysis of Canada’s Westminster parliamentary

system and the U.S. presidential system. Research that was done proved that parliamentary

systems are more effective, more accountable, and create a stronger and cohesive party

system. The main fault of the U.S. system is the separation of powers system, creates a

bureaucracy that is buried in formal restrictions causing inefficiency when it comes to policy

45
Ibid. 287
46
M. Moe and Michael Caldwell, “The Institutional Foundations of Democratic Government: A comparison of
Presidential and Parliamentary Systems”, Journal of Institutional and Theoretical Economics 150 (1994), pp.
171-195, pp. 175

12
making. The U.S. government is consistently less effective, having division of powers and

separate elections can cause disagreements between the different levels of government, which

leads to instability in the system. I feel that what makes parliamentary systems the preferred

system is responsible government. Responsible government makes sure that each level of

government is accountable for each other, which allows for a stable and efficient system.

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14