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“Civil Rights” Policy in the United States and the Policy of “Integration” in Europe: Divergent Approaches to a Similar Issue

Published online by Cambridge University Press:  14 October 2011

Gérard Noiriel
Gérard Noiriel
Affiliation:
Ecole Normale Supérieure, Paris
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Extract

Comparing European and North American policies with respect to “civil rights” is a difficult exercise for two reasons. First, it is important to emphasize that Europe and the United States are not political entities of a same nature. Granted, the fact that the nations that today comprise Europe are heirs of common history explains in part the similarities in their political behavior and distinguishes them as a group from the “New World.” Yet in the American case, despite the country's federalist structure and the existence of fifty states within the Union, we are dealing with a single nation, endowed with a central government capable of generating policies that are valid throughout the territory. Such is not the case with Europe. As is well known, the European continent is divided into two sharply contrasted spheres. On the one hand, there is the East, thrown into confusion by the devastation of communism and mired in a profound economic crisis. On the other hand, there is the West, comprised of nations that share a level of economic prosperity comparable to that of the United States but which do not form a single political entity. At present, the European Economic Community includes only twelve European states; the remaining countries, such as Switzerland, Sweden, and Austria, have yet to become members. In this essay, the question of “civil rights” will be examined specifically in light of those countries that already belong to the EEC.

Type
Articles
Information
Journal of Policy History , Volume 6 , Special Issue 1: Civil Rights , January 1994 , pp. 120 - 139
Copyright
Copyright © The Pennsylvania State University, University Park, PA. 1994

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References

Notes

1. See Graham, Hugh Davis, The Civil Rights Era (New York, 1990).Google Scholar

2. This expression is put in quotation marks because, as we shall see, some researchers deny the existence of such minorities.

3. de Tocqueville, Alexis, De la Démocratie en Amérique (Paris, 1981)Google Scholar, with an important preface by F. Furet: “Le système conceptual de la ‘Démocratic en Amérique,’” 7–46.

4. Ibid., 454.

5. Ibid., 457.

6. This occurred even in the formal colonial empire, albeit in a context of extreme racial and ethnic diversity. On these differences between France and the United States, see Noiriel, Gérard, The French Crucible (Minneapolis, 1994Google Scholar; French edition 1988).

7. Tocqueville, Démocratie, 134.

8. This explains why in all the European countries, participation in elections is stronger than in the United States, frequently attaining 70 percent to 80 percent of the electorate.

9. Social deductions vary between 40 percent and 50 percent of the GNP in Europe, which is much higher than in the United States or Japan.

10. These figures are not precise. On the one hand, they account for internal migrations within Europe (for example, in Germany a quarter of the foreign population comes from other EEC nations; and in France the Portuguese, European citizens, are the largest single immigrant community). On the other hand, the figures exclude African and Asian emigrants who remained citizens of the host country when the colonies proclaimed independence. (These national immigrants comprise a significant share of the total population in Great Britain and Holland.)

11. Castles, Stephen and Kosacks, Godula, Immigrant Workers and Class Structure in Western Europe (New York, 1973).Google Scholar

12. On this issue, see Hammar, Thomas, ed., European Immigration Policy: A Comparative Study (Cambridge, 1985)CrossRefGoogle Scholar, and Schnapper, Dominique, L'Europe des immigrés (Paris, 1992).Google Scholar

13. Schnapper, Dominique, L'Europe de l'intégretion: Sociologie de la nation (Paris, 1991).Google Scholar

14. Unlike in other European nations, which have long been countries of emigration, France has been a country of immigration only since the nineteenth century.

15. On the differences between French and German definitions of citizenship, see Brubaker, Rogers, Citizenship and Nationhood in France and Germany (Cambridge, Mass., 1992).Google Scholar

16. Dummett, Ann and Nicol, Andrew, Subjects, Citizens, Aliens, and Others: Nationality and Immigration Law (London, 1990).Google Scholar

17. Whereas until then nationality law had been, as in the United States, exclusively grounded in jus soli, in 1971 for the first time the government introduced jus sanguinis by adding the notion of “patrial” to British law. The 1981 British Nationality Act further reinforced these dispositions. Today, even the children of ethnic minorities have trouble becoming British citizens.

18. In Germany as well, although the situation varies from one länder to another, ethnic minorities were granted the right to vote in local elections (notably in Hamburg) and to a specific education. Muslim religion is taught in public schools in accordance with programs established by the University of Cairo; with Muslim educators paid by the German state. Native minorities, such as Frisians and Danes, obtained recognition of their cultural identities.

19. Lijphart, Arend, The Politics of Accommodation: Pluralism and Democracy in the Netherlands (Berkeley and Los Angeles, 1975).Google Scholar

20. Sieghart, Paul, ed., Human Rights in the United Kingdom (London, 1988).Google Scholar

21. See Jenkins, Richard and Solomos, John, eds., Racism and Equal Opportunity in the 1980s (Cambridge, 1987)Google Scholar, and Edwards, John R. and Batley, Richard, The Politics of Positive Discrimination (London, 1978).Google Scholar

22. In France as well, many immigrants from the former colonies enjoy full civil rights, but as French citizens. Such is the case, in particular, of residents from the Overseas Departments and Territories (the Antilles, French Polynesia, and the islands of Réunion). Citizens of the former colonies, however, legally became foreigners at the time of independence. In certain cases (such as Algeria), they could nonetheless choose between French nationality and that of their country of origin.

23. Didier Lapeyronnie and Marcin Fribes (with the collaboration of Cooper, Kristin and Joly, Daniele), L'Intégration des minorités immigrées: Etude comparative France-Grande-Bretagne (Paris, 1990).Google Scholar

24. Since 1901, associations in France had depended on private law; they are therefore juridically separate from state institutions.

25. See Lloyd, Cathie, “Concepts, Models, and Anti-Racist Strategies in Britain and France,” New Community 18 (October 1990): 63–73.Google Scholar

26. Only since reunification have the German people enjoyed territorial boundaries that pose no major political problems.

27. Patriotism is of course as pronounced in Great Britain as it is in France, but it is expressed through loyalty to the royal family rather than through nationality.

28. Crowley, John, “Le Rôle de la Commission for Racial Equality dans la représentation des minorités ethniques britanniques,” Revue Européenne des Migrations Internationales 6 (Fall 1990): 45–61.CrossRefGoogle Scholar

29. Lapeyronnie and Fribes, L'Intégration.

30. The term “colored people” is also considered racist in France, considering that everyone, whites included, has a skin color. It must be recalled that the community of French citizens includes several million blacks (if immigrants are added to individuals residing in the Overseas Departments). Numerically, they are a larger group than those of North African origin.

31. To compare with the American model, see especially Horowitz, Donald, “Immigration and Group Relations in France and America,” in Horowitz, Donald and Noiriel, Gérard, Immigrants in Two Democracies: The French and American Experience (New York, 1992).Google Scholar

32. Quoted by Crowley, John, “Le Modèle britannique d'intégration,” Migrations-Sociétés 24 (November–December 1992): 37–45.Google Scholar

33. Daily Express, 8 April 1992, quoted by Hargreaves, Alex, “Islam, education et politique,” Migrations-Sociétés 24 (November–December 1992): 56–67.Google Scholar

34. See Sudre, Frederic, Droit international et européen des droits de l'homme (Paris, 1989).Google Scholar

35. The restrictive nature of this convention for European governments is illustrated by the reticence many of them manifested prior to signing. France delayed ratification of the text for twenty-four years. While twenty-one countries of the European Council have signed the Convention, seventeen did so after expressing reservations on one or more articles they deemed unacceptable.

36. European institutions have been used to defend their civic demands, particularly those related to minority languages. In 1981, the European parliament voted to adopt a charter on linguistic and cultural rights for minorities. In 1982, a European bureau of the least widespread languages was created. And in 1988, the European Council Assembly adopted a project for a European charter of minority languages and cultures, which France was able to ratify only by amending the second article of its Constitution, which states that “the language of the republic is French.” See Giordan, Henri, ed., Les Minorités en Europe (Paris, 1982).Google Scholar

37. This is also because Great Britain is today a poorer country than France (its GNP is 28 pecent lower).

38. Wacquant, Loïc J. D., “The Comparative Structure and Experience of Social Exclusion: ‘Race,’ Class, and Space in Chicago and Paris,” in Lawson, R., McFate, C., and Wilson, W. J., eds., Urban Marginality and Social Policy in America and Western Europe (Newbury Park, Calif., forthcoming).Google Scholar

39. Glazer, Nathan, Affirmative Discrimination: Ethnic Inequality and Public Policy (New York, 1975).Google Scholar

40. The greater gravity of racist acts in Great Britain can be attributed to the fact that they tend to be collective, whereas in France they are typically committed by isolated individuals. The problem raised here is clearly that of statistical recording. That the surveys are equally trustworthy and measure the same phenomena in both countries would have to be verified.

41. For the English case, see Gilroy, P., There Ain't No Black in the Union Jack (London, 1987)Google Scholar. For the United States, see Pinkney, Alphonso, The Myth of Black Progress (New York, 1984).Google Scholar

42. We know that in practice Americans reject the terms “immigrants” and “foreigners” to designate ethnic minorities because these terms are regarded as xenophobic.

43. Naïr, Sami, Le Regard des vainqueuers (Paris, 1992).Google Scholar

44. In France the National Front, the leading party of the far right, now routinely obtains between 10 percent and 15 percent of the vote. On the issue of racism in France today, see Taguieff, P. A., ed., Face au racisme (Paris, 1992).Google Scholar