EDIT: I'll admit I overlooked the US system's origins origins and concepts in France - but even though these concepts are not American in origin, the US is where all the mentions lead-to today.
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It is an Americanism because the term implicitly assumes two things:
1. That the government is split into branches, following how the US system evolved.
2. That executive power must be confined to a single branch, also how the US is organized.
Then, consider that other-countries-that-are-not-the-US do exist, many of those are liberal democracies that arguably function better than the US for various scores - and of those very few (if any?) of those are modelled on the US’ system. While some other countries have a US system but score poorly overall (e.g. Liberia).
It is demonstrable that deep separation between the agents of the government - and the state - is unnecessary for a functioning liberal-democracy today: many countries using the Parliamentary system have an executive cabinet and an executive PM role which, under the US system, is considered part of the legislature - and the US is hardly the best example of “separation” of the judiciary when you consider how explicitly political the judge appointment process is - and the volume of politically-motivated and arbitrary SCOTUS rulings over the past 120+ years.
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I understand that (non-crackpot) political-scientists would agree that judicial independence alone is far more important to a functioning democracy than a system that constantly pits an executive President against the legislature whenever their political party affiliation differs.
Don’t get me wrong: accountability is of paramount importance; I just want to communicate that having “separate but co-equal branches of government”, “separation of powers” (and other thought-terminating-cliches from middle-school civics class) is both unique to the US - and is demonstrably unnecessary for a functioning liberal democracy.
> It is an Americanism because the term implicitly assumes two things:
> 1. That the government is split into branches, following how the US system evolved.
> 2. That executive power must be confined to a single branch, also how the US is organized.
I'm pretty sure these principles are originally French. The American system was built around these principles as well, but calling them American is a whole new level of Americentrism.
Separation of powers into three branches is basically a prerequisite for belonging to the EU, as it is considered a basic requirement for a democracy.
For that matter, the US and France are probably two of the modern democracies that have the least separation between these powers (on paper).
> I'm pretty sure these principles are originally French. The American system was built around these principles as well, but calling them American is a whole new level of Americentrism
I'll concede that - certainly.
> Separation of powers into three branches is basically a prerequisite for belonging to the EU, as it is considered a basic requirement for a democracy
The EU is concerned more with judicial independence, not constitutional separation-of-powers: most EU countries (and especially its founding and early members) do not have separation strictly along judicial/legislative/executive boundary lines: The UK, Germany, Spain, and others all have an executive parliament; France and the US are in the minority here.
> most EU countries (and especially its founding and early members) do not have separation strictly along judicial/legislative/executive boundary lines
1. Let's not count the UK because it's the earliest democracy, and also is the messiest one (no written Constitution...) and also it's not the earliest or current member of the EU.
2. What exactly is an 'executive parliament'? My understanding is that in parliamentary democracy, the parliament chooses the executive, but the executive powers lie solely with the executive (government), and the parliament in itself does not have any direct executive function. It can only legislate, not execute. Certainly that's the case for Germany and Central European parliamentary systems I know a little bit more of. Might be different in the US but we are talking about the EU now.
Sorry - I was being sloppy and made-up a term that at-the-time made sense to me but I didn't proofread my post...
But I was referring to any parliamentary system where executive power is held by (a subset of) the members of that parliament (i.e. how the PM's cabinet's members are MPs) - basically what Canada and the UK has, for example.
Ah ok now I understand. Don't know about Canada but the UK is certainly an exception in this regard. In Germany and rest of Central Europe the PM and ministers are not required to be MPs, in fact currently in Slovakia we have a interim government without any MPs at all. Also in Slovakia when a MP is made PM or member of government he is temporarily released from the parliament and a substitute from the party list is temporarily taking his MP place. In some other countries sitting MPs while in government still have to take care of their MP duties.
---
It is an Americanism because the term implicitly assumes two things:
1. That the government is split into branches, following how the US system evolved.
2. That executive power must be confined to a single branch, also how the US is organized.
Then, consider that other-countries-that-are-not-the-US do exist, many of those are liberal democracies that arguably function better than the US for various scores - and of those very few (if any?) of those are modelled on the US’ system. While some other countries have a US system but score poorly overall (e.g. Liberia).
It is demonstrable that deep separation between the agents of the government - and the state - is unnecessary for a functioning liberal-democracy today: many countries using the Parliamentary system have an executive cabinet and an executive PM role which, under the US system, is considered part of the legislature - and the US is hardly the best example of “separation” of the judiciary when you consider how explicitly political the judge appointment process is - and the volume of politically-motivated and arbitrary SCOTUS rulings over the past 120+ years.
———
I understand that (non-crackpot) political-scientists would agree that judicial independence alone is far more important to a functioning democracy than a system that constantly pits an executive President against the legislature whenever their political party affiliation differs.
Don’t get me wrong: accountability is of paramount importance; I just want to communicate that having “separate but co-equal branches of government”, “separation of powers” (and other thought-terminating-cliches from middle-school civics class) is both unique to the US - and is demonstrably unnecessary for a functioning liberal democracy.