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First draft – please do not cite without permission of the Author.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.
Karol Chwedczuk-Szulc, University of Wroclaw, Poland
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.
Karol Chwedczuk-Szulc, University of Wroclaw, Poland
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
Karol Chwedczuk-Szulc, University of Wroclaw, Poland
(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)
Karol Chwedczuk-Szulc, University of Wroclaw, Poland
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
Karol Chwedczuk-Szulc, University of Wroclaw, Poland
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
Karol Chwedczuk-Szulc, University of Wroclaw, Poland
• 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.
Karol Chwedczuk-Szulc, University of Wroclaw, Poland
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)
Karol Chwedczuk-Szulc, University of Wroclaw, Poland
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.
Karol Chwedczuk-Szulc, University of Wroclaw, Poland
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.
Karol Chwedczuk-Szulc, University of Wroclaw, Poland
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
Karol Chwedczuk-Szulc, University of Wroclaw, Poland
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
Karol Chwedczuk-Szulc, University of Wroclaw, Poland
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.
Karol Chwedczuk-Szulc, University of Wroclaw, Poland
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.
Karol Chwedczuk-Szulc, University of Wroclaw, Poland
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
Karol Chwedczuk-Szulc, University of Wroclaw, Poland
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.
Karol Chwedczuk-Szulc, University of Wroclaw, Poland
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.
Karol Chwedczuk-Szulc, University of Wroclaw, Poland
Karol Chwedczuk-Szulc, University of Wroclaw, Poland
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