Compare the scope of, and limits to the powers of the President of the USA, the British Prime Minister and the German Chancellor.

Before looking at this question, it is important to insert a clear disclaimer. Every trend, observation and generalisation in this subject seems to be able to be dismissed with a counter example from post-war history. Trends seem to be identified and then disproved. For example, Presidential impeachment was once seen as an irrelevant constitutional nicety, reserved for extreme examples that could never be envisaged. Later, due to the actions of President Nixon, it became relevant as a way to removing a President after their abuses of office. Today, impeachment seems to be just another partisan tool with which to discredit an administration. Similarly, for the large part of her reign, PM Thatcher's government backbenches were toothless and secondary to the will of the executive. This was contrasted clearly to PM Major who was held hostage by rebel Euro-sceptic backbenchers. To dismiss the thought that Majors years were starting a new trend in executive-legislative relations, PM Blair's backbenchers are operating merely as legs for the party pagers to move through the division lobbies. Much the same again could be seen by contrasting the Chancellorships of Adenauer, Schmidt and Kohl in Germany.

The point that is seemingly being alluded to is that individuals shape executive leadership and as such any study as this is fruitless. This would surely give a strong excuse to finish this study here. Unfortunately, although people matter, it was not only the individuals that were the difference between the Johnson, Reagan or Clinton administrations. Instead definable factors (some of which might have led to certain personalities gaining office; a divided Tory party led to the need for a weak, Major figure after Thatcher) which will set the scope and limits to the executive. My disclaimer is not therefore that it is irrelevant to carry out such a study, but instead that the multitude of competing factors that will affect such a study makes clear conclusions, patterns or generalisations impossible to make; certainly to be of any prescriptive use.

The concept of power must be central to this study. Power, in its rawest form must be the ability of one actor to cause another to act in a way that it would not normally do, to better the powerful's interests. It is easy to see a confrontation and declare they who triumph as the powerful. Harder to identify are areas whereby power is used without the other party knowing that in fact they have acted towards your interests; that they are oblivious to the power relationship. This could perhaps be the difference between power through education to your case compared to bargaining power. There is of course many shades of grey between these two extremes. Because of the visibility of conflicts between groups, the softer form of power, usually marked by consensus, largely goes unnoticed, yet to many administrations, it is one of their greatest tools.

This study will look firstly at the various institutional hurdles and the perceived role of the leadership in each of the states. These should point to at least the extremes of possibilities to the scope and limits of power. Following this, I shall try and identify possible tools that the President/PM/Chancellor has to exert these powers with greater strength, and what outside factors will affect such pursuits. The last section will be one of application, to test to what extent the predictions made in the previous sections can be justified in each state.

Institutionally, there is great similarity between the position of the leaders in the US, Germany and the UK. The extreme case of limits of the power of a leader is the ability of others (excluding the electorate) to remove them from office. On this basis, the US President seems to be institutionally strongest. To be removed, constitutionally, there is a need for votes in the two chambers of the legislature, including a trial and must be on the basis of treason or 'high-crimes or misdemeanours'. Further, a two-thirds majority in the Senate is required for removal. This is largely due to the strength a President has of being directly elected for the post by the people, unlike in the UK or Germany. The next hardest to remove is the German Chancellor. Unlike the case of the US President, there is no need for justified reason for removal from office. What is necessary is what is termed the 'constructive vote of no confidence'. Due to the post-Weimar paranoia of the Basic Law authors, a Chancellor cannot be removed unless there is a positive vote in the legislature for another candidate to be their successor. The difficulty in building such an alliance has made such circumstances unlikely, although this was the mechanism by which Helmut Kohl first gained power. The British PM can be removed internally by members of their own party. The PM is the leader of the party with a parliamentary majority, but unlike in Germany, the selection of this leader is according to the details of party constitutions. This further highlights the difference between a centralised system of governance of the UK and Germany, compared to the separated government of the US (I am deliberately ignoring the federal dimension of the US and Germany out of practicality).

In the US, the legislative branch has according to the Constitution sole power over the framing of legislation. The President may suggest legislative programmes in the State of the Union address, but otherwise, there are no other constitutional mechanisms for him to legislate. This observation has led to Richard Neustadt's notion of Presidential power (in legislation) as being that of the "power to persuade". The tools with which this can be done will be discussed later, but this is an important feature to remember. It is feasible for Congress to ignore the President and so give him no power whatsoever in legislation, with the only possible limit to this being the use of the veto, or though threat of Presidential veto, as a 'line-veto'. This contrasts with the United Kingdom where the executive is the predominant source for legislation being put forward. There is some scope for non-governmental bills to be proposed, but these rarely pass onto the statute books and are often used simply as a means for publicising causes. The British Prime Minister (and so the rest of the executive through collective responsibility) lead the legislature, indeed they are predominantly part of it. It is therefore the role of opposition to limit the assumed power of the executive (by virtue of a tightly whipped majority), rather than the role of the executive to enforce itself on a hostile legislature. Rarely are government bills defeated in the House of Commons. When they are defeated, it is often such an event that votes of confidence follow. A PM with a strong, united majority is easily classified a being a de facto 'elected dictator', with very little to prevent passage of legislation.

The German system again slips between those of the US and the UK, although more towards the UK. In Germany, the possibilities of British style dominance are diluted by the strains of coalition building and maintenance within the legislature. Presence of coalition members in the executive and collective responsibility (although weaker than in the UK, because of greater separation of government departments) means that some degree of discipline can be relied upon. Such need for consensus does mean that whilst an executive can seem to have the bargaining power to pass its legislation through the legislature, the legislation is often weaker than originally wanted due to behind the scenes pre-drafting negotiations.

The next area to look for the power of the President, PM and Chancellor is in relations to the rest of the executive. It has previously been hinted that because of conventions of collective responsibility, the executive can be seen as an extension of the leader. This is largely true when looking at how the executive relates to other institutions, but internally, the dynamics of executives can highlight limits and extremes of a leader's power. Whilst all three of these states have some form of notion of cabinet government, the UK is the strongest case. The British cabinet meets frequently and discussions between Cabinet ministers will form government policy. Whilst there is some autonomy of a Secretary of State over their department, it is secondary to the will of the cabinet. This contrasts with the system in the US where the cabinet meets as a whole extremely rarely, a few times a year. Little cross-departmental decision making is done in such meetings, instead it is a platform for the President to show his troops that they are part of a team, or to mislead them about what they did with interns (I'm assuming that isn't a trend to watch out for in the future). German cabinet ministers are again responsible for their departments, with the Chancellor largely dictating to them the thrust of major policy initiatives. Because of the formation of coalitions, many of the large policy decisions would have been previously negotiated and clarified.

Another interesting part of the executive is its composition. Here again, the President displays the most power. He can largely choose whoever he wishes. An extreme example of this is the current Secretary of Defence, William Cohn, who is a declared Republican. Appointments are made on the basis of who the President feels will succeed in the role and carry through their policies. Removal, again, is by the President. The German model is the furthest from this. Here, coalition agreement will often dictate the formation of the executive, with often new departmental roles being created in order to satisfy coalition partners. Removal of ministers would have to be with the consent of coalition partners. The British case fits between these. The PM can theoretically appoint anyone that they choose, but convention is for ministers to have seats in Parliament (either House) and be part of the same party. Occasionally others can gain seats in government, such as trade unionists under Labour governments, but because of ministerial accountability to Parliament, this is rare. Because British parties are renowned for having factions, it is typical, but not necessary for ministers to represent a range of views from within the party in order to maintain Parliamentary discipline and unity.

The next area in which a leader can exert power is by those means which no not require support from other branches of government. An important example of this is in relation to foreign affairs. As Commander in Chief, the President is able to order military action without the need for consent from other branches. Indeed, in such matters, other institutions, advise the President, but cannot overrule. Congress does have powers to refuse financing of actions it does not approve of, but such action is too slow to be largely practical. Further, leaders in all three states can exert power in the international arena through diplomacy. Such actions cannot be limited by other branches directly. Examples of such mechanisms include hosting of summits. The British PM is in a similar position to the President, although often there does seem to be closer partnership and co-ordination with other members of the executive, such as the Foreign or Defence ministers. The constitutional constraints on the German military mean that such powers over the forces are limited in Germany, and action often comes through consensus.

The last institutional feature to look at is that of executive power over the bureaucracy. This is often hard to identify, but there are some key institutional differences that could make the different executives more powerful in these relationships. The first, is the difference between the permanent bureaucracies of Britain and Germany and the ability of the US President to appoint much of the top levels of their bureaucracies. The ability to appoint bureaucracy members not only encourages loyalty, but also limits the chance of other interests conflicting with those of the President. The bureaucracy is important because it is one of the greatest sources of information to an executive and so it has the power over the leader by being selective in how it passes information on. The 'Yes, Minister' model of the British civil service is a caricature of how such power can operate. Presidential appointments can reduce this as there will be less of a hidden agenda from the executive. The difference between the size and appointment nature of the relative staffs of the White House and 10 Downing Street are testament to a few of the features noted. Many of the functions taken on by the White House are delegated to other institutions, such as the Cabinet office by the British Prime Minister. Whilst there are political advisors in Downing Street, they are often seen as below the highest civil servants and there is pressure on the PM not to politicise the civil service. The size of the job of leading a state means that leaders are heavily dependent on those around, so if you have the power to make sure that those around follow your own agenda, you have greater power in advancing your own interests.

An important limit to power to note here is that of the on-going political agenda. A leader (this point goes for all three states) can come to office as a new administration, but this does not mean that the bureaucracy is frozen, waiting for their instructions. Actions of an administration's predecessor will be on-going policy, and it will often be the job of the new administration to continue such measures. There will also be non-legislative workings of the bureaucracy in operation that must be addressed by the new executive. Leaders are unable to completely dictate the political agenda and workings of the bureaucracy.

The next section of this study is to look at some of the tools that are available to the leaders in order to best exploit the institutional possibilities for their use of power. The first important tool is that of an electoral mandate. This is perhaps of greatest use in the UK where elections are won on party manifestos, with the government being made up solely (ignoring exceptions such as Liberal Democrat participation in some Cabinet committees) of the victorious party. There is even the Salisbury convention in the House of Lords, whereby they support anything that was part of an election manifesto. Unlike in the US, each candidate is (largely) running according to this consistent party-line. The style of party-centred campaigning and voting behaviour further gives the Prime Minister a personal mandate, although not personally elected. A similar case can be presented for Germany. Although the coalition nature means that perhaps the ruling coalition as a whole does not have a mandate, the Chancellor does come from the largest party and the coalition agreement shows that the partner does give him an indirect mandate on behalf of their electorate. This mandate can also be used as a tool to gain power over the civil service and change their on-going agenda.

To apply the term 'mandate' to US politics is a far harder task, certainly for particular policies. For a President alone this would be true, a diverse electorate numbering over a hundred million people (assuming about 50% turnout) would not be expected to be able to reach any form of consensus. But unlike in British or German elections, the US President does not come from the largest party, but is elected separately, often at the same time as the legislature. The phenomenon of split-ticket voting must if not complicate the mandate, suggest that all sides (assuming split-party government) can claim one for themselves. This means that as a tool, the Presidential mandate is not particularly strong to press for specific measures, although it can be used as a tool to suggest the people's support for their judgement. It is worth mentioning that because of the difference in election dates, the mandate can work against a President. The most clear case of this point was the Contract with America in which the GOP claimed a mandate from the 1994 House elections.

Another identifiable tool for greater power is that of a strong party presence in the legislature. Again, this is a greater tool in the UK and Germany where party discipline can be relied on greatly. The members of the legislature are (largely) elected on the same platform as the leader and so can be relied on to support their legislative initiatives. This carries through for coalition agreements in Germany, although rebellions are more likely in such a case. In the US, while it is a great help to have a strong party presence in Congress it is not necessary. Cross-party voting is far more common and often Presidents find alliances with the opposing parties (for example Clinton with the GOP over NAFTA). When there are partisan splits, such as on issues which are typically identified with the differing parties, such as race, it is clear that a legislative majority gives the President greater power. Another point to mention here is that although empirical evidence does suggest that as much legislation is passed under split-government as under single-party government, it is possible to assume that the strength of legislation is stronger under single-party domination. The compromises are made before suggesting the legislation as it is know that it must be acceptable to the other party to go anywhere. For this reason, in a more subtle way, the President has greater power in pushing through his interests, which are a more interesting measure than simply counting number of policies which end up as law.

In the British case, variation in how a PM organises their cabinet can greatly influence how much direct power they have. Because this situation is greatly incomparable to the leader centred cabinets of the US and Germany, it is not necessary to give great detail in variations here. It is possible to perhaps simplify the strategies into two. The first is the clique centred cabinet, whereby the PM gives the major jobs and heading of major cabinet committees to close allies who will follow the PM's line. This is necessary because of the limits of the actual time that an individual has to personally control the agenda. The opposite extreme to this example is that of the PM acting as mediator between factions within a cabinet. In such cases the cabinet would not be led by an inner clique, but instead negotiation and consensus would be tried to be mediated by the PM. It is clear that the first style would give the Prime Minister more power than the second, although collective responsibility might prevent identifying what form of cabinet is occurring.

Such an arrangement of lack of Prime Ministerial dominance in a cabinet is a feature of another factor on the power of a leader (in all three cases); that of unity within a party. Many of the arguments for this are related to those of having a large party presence in the legislature. This becomes especially relevant when a party has a small majority. In the US, cross-party voting is generally expected (because of the variety of regional interests of Representatives), so any party cohesion is a bonus. In the UK and Germany, where party discipline is to be expected, a lack of party unity or factionalisation can greatly weaken the leader's hand. This can come in the form of the dilution of policy, or in having to build a cabinet which does not act as an extension of the will of the leader (more so in the UK because of stronger cabinet decision making). As hinted at before, there is little chance of embarrassing defeats in the legislature because strategy and bargaining takes place often in private, but still the threat of such an occurrence is enough to greatly limit a leader's powers. The same argument can easily be extended for unity within a coalition partnership in Germany.

The last tool that I wish to suggest that a leader could use is that of popularity. This is again relates to other factors mentioned, and can even be a by-product of it. A President is limited to the 'power to persuade'. He must persuade Congressmen with no direct link to him, that they will benefit by supporting the President. It doesn't take a cynic to note that politicians are easily tempted by the chance of staying in office. Therefore, to have some of the Presidents popularity reflected onto you, because of your support for him, you can gain yourself electoral popularity. This is again especially important in the US where Congressional elections take place every other year. This means even in a year a President isn't campaigning for himself, or is in a 'lame-duck' period of a second term, popularity with the electorate is an important tool. Similar arguments can be made in the UK or Germany. Being seen as a rebel against a popular Prime Minister or Chancellor might be electoral suicide, although because votes are usually cast on national, party lines, this factor is limited. From the identification of this tool, it is easy to understand why ability or inability to manage the media agenda could be a major asset or limit to executive power.

The last part of this essay is to see if the institutional theory outlined above can be seen to occur in reality in each of these states. The study has concentrated on the institutional considerations and so it must be noted that these will only give a limited answer. Social factors, such as strength of social movements or the state of the economy will also greatly affect leadership power, as will a multitude of other factors. This moves back to the original disclaimers, but I believe there is still some value in looking at each state briefly in turn, to see if they correspond to predictions. For simplicity, I shall try and use the most modern examples, if only for consistency of comparison as changing times are a factor in themselves, such as due to the advent of technology leading to greater candidate centred campaigning.

The case of the Presidency of Bill Clinton alone highlights how changes in institutional factors can show the limits and scope of Presidential power. When Clinton came into office, he was faced with a House controlled by his own party and an agenda which he felt mandated to pursue. His first years in office were greatly productive, using many forces available to him, even using cross-party voting against his own party to secure the NAFTA agreement. This period was then eclipsed by Newt Gingrich's success in the 1994 House elections under his Contract with America platform. This not only made the House a different party, but it was a party which believed it had a clear mandate. Its first hundred days in office were incredibly productive and effectively froze the President out of policy making, he was even reluctant to threaten his veto. After this period, the unity of the GOP decreased, giving Clinton again the opportunity to work for bipartisanship towards the next election. Bipartisanship as a comparison to the system after the GOP's victory was a positive increase in power for the President. This was coupled to unprecedented Presidential approval ratings and resulted in the gaining of a second Presidential term. As Clinton entered his second term he was able to continue bipartisan participation with the House, as well as using his time to act in areas where he was independent of other branches. This is what many have called his 'legacy building', by actions such as the brokering of peace in Israel and Ireland. There have been some major triumphs in this period, such as the budget resolution, which was a policy in which he was able to gain GOP consensus. In areas unpopular to the GOP, he was less successful, such as in his attempts to make major reforms of health-care and social security. Lastly, impeachment must be mentioned, although I believe with regard to this question it is largely irrelevant. Clinton did manage to at least have some power over Democrats in Congress during the highly partisan impeachment hearings. This is largely irrelevant because (taking the safe assumption that there will not be 66 votes in the Senate) his popularity is still incredibly high and his 1999 State of the Union address was full of positive measures, many of which seem palatable to large sections of the GOP.

By looking at the changing periods within Clinton's Presidency, many of the factors discussed above can be seen to have had an effect on his powers. The inverse of much of this can be seen during the Bush Presidency which was less productive, possibly due to the Democratic House and his personal unpopularity (and "the economy, stupid"). There is still great difficulty in deciphering the effect of more subtle factors, such as the role of an on-going agenda or the extent that policy was diluted. This is simply because, as was suggest above, power is more overt when there is a conflict when someone backs down. In US politics, however, many conflicts end with both sides claiming victory.

In the UK, elective dictatorship does seem to hold as a model for executive power over the legislature. Even in the days of Major, government sponsored bills rarely were defeated. This does not suggest for a moment that he had equal powers to Thatcher (in the mid-80's) or Blair. He won votes, but often because his policies were watered down so that they would suit all factions of the Tory party. The weakest point came when he was backed into taking a strategy of "back me or sack me" when he resigned as leader of the Conservatives. This is a striking contrast to Blair's government. Blair has a majority so large there isn't seating in the House. This allows the Labour executive to bring in measures which are radical and even unpopular to large sections of his own party, such as the abolition of student grants. The nature of the 1997 election was extremely candidate centred and so when the PM first spoke to his new MP's he stressed that New Labour was elected and New Labour had been given a mandate, not the individuals. This was broadly correct and the possibility of governmental jobs is more than enough to secure that pagers will not be turned off. The size of Blair's majority seems to compensate for anything that might work against the administration, such as suggested splits within the cabinet (particularly with Chancellor Gordon Brown) and descent from traditional Labour voters. Thatcher in contrast was the basis for a model of clique centred cabinets, heavily controlled by her personally. There is an impression that whilst Blair is largely powerful in the government, there are other, often complimentary loci of power, such as (until recently) the position of Peter Mandleson. Again, relations with the bureaucracy are hard to measure.

The German case largely seems to agree with the theory above. Legislation in Germany (both pre and post unification) was typically seen as being weak. This is due to the constraints put on the executive (and so the Chancellor) by the practicalities of coalition building. Within these constraints different Chancellors have been able to be more or less effective. For example Adenauer, the first Chancellor of the post-war Federal Republic was extremely powerful within his government, even taking on the role as foreign minister. Others, because of their lack of legislative support and weak coalitions, such as Schmidt, have been far less able to be in control of the legislature. The new coalition between the SPD and the Greens, under Schroder has again the potential to be weak. Although legislative representation for the coalition is strong, it has been suggested that the anti-establishment nature of Green politics makes them a less reliable partner than the FDP. It is, however, too early to tell since the elections of September 1998.

In all, although there are similarities between the states, such as cabinets and legislation moving through legislatures these are superficial. The peculiarities of institutions of each system makes trends extremely vague. Even within a state, social factors and personalities can affect how leader power is used. There are some key factors that can give a clue, such as size of legislative majority, unity of party and personal electoral popularity, but these can be overshadowed by other factors to change trends. For this reason, it is seemingly impossible to compare for any prescriptive use the powers of various leaders. Studying cases can, however, show what factors are predominant during any particular administration.