The death of Queen Elizabeth and the coming coronation of King Charles III on May 6 have focused attention on the institution of the British monarchy at the same time that we Americans have been pondering the presidency in the light of four years of Donald Trump in the White House, the insurrection he fomented on Jan. 6, 2021, and the refusal of many to accept Joe Biden as the legitimate winner of the 2020 election.
In Great Britain, the succession of a new monarch has happened smoothly and has helped provide stability amid the recent string of prime ministers who proved unsuitable for or inadequate to the job. (Still, it should be noted that Jacobites, supporters of the Stuart line of King James II, who was deposed in 1688 after he became a Catholic, say that it is his grandson, Charles Edward Stuart, who had rightful claim to the title King Charles III.)
The contrast between the position, powers and prerogatives of a British monarch and an American president raises some interesting questions. In the British system, the positions of head of state and head of government are separate, and the head of state plays a mostly ceremonial role. This is also the case with the other European monarchies, though in some republics it is the president’s office that is mainly ceremonial. Then there are republics with strong presidents (like France) who share or delegate power with premiers or prime ministers. The United States is one of the few countries where the same person is both head of state and head of government, on the one hand representing the dignity and unity of the state and, on the other, in charge of the executive branch of government.
The United States is one of the few countries where the same person is both head of state and head of government.
What is truly fascinating is that at a certain point in the late 18th century, the British monarch and the American president occupied the same position relative to their roles in the governance of their countries. The great British historian of the United States, Lord Bryce, in his The American Commonwealth (1885) points out that when the Founding Fathers at the Constitutional Convention cast about for a model for the executive of their new nation, what they had at hand was the British monarch, King George III—whom, of course, they had recently vilified in the Declaration of Independence!
George III, at that stage in the evolution of the British monarchy, still had considerable executive power. He appointed government ministers, and they were answerable to him more than to Parliament. It was truly the king’s government.
The king could not, it is true, govern without Parliament, especially with regard to raising and spending tax revenue, but he could propose legislation for Parliament to consider. He could (and did) veto measures passed by Parliament, and it was the responsibility of his ministers to smooth the way for the “king’s business” in Parliament, not least by distributing royal patronage and honors. It was, if you will, a system of checks and balances, but the king had real power and was an essential party in that balance.
At a certain point in the late 18th century, the British monarch and the American president occupied the same position relative to their roles in the governance of their countries.
Over the course of the 19th century, the position of the monarchy in the unwritten British constitution changed, especially with the emergence of mass political parties, an executive branch responsible to Parliament, and a cabinet system wherein the prime minister is the clear head of government and ministers are answerable to him, not to the monarch. By the end of Queen Victoria’s reign, this change had been largely accomplished, and the only remnant of the king’s official role in government was the “kissing of hands,” when a new prime minister is asked by the monarch to form a government (as happened twice within a month last year).
By contrast, the position and powers of the U.S. president, as defined in Article II of the U.S. Constitution, are fixed, and those powers have not been appreciably altered either by the 22nd Amendment (which limits the president to two terms) or the 25th Amendment (which provides for the replacement of a president after death or resignation). They are in many ways the same powers exercised by George III at the time of the American Revolution.
We have seen in our country, especially in recent years, the problems associated with having both offices united in one person who is almost impossible to remove from power.
That is, the president is head of the executive branch, and ministers (cabinet secretaries) are appointed by and answerable to him for the running of their departments. The president can propose legislation to Congress and he can veto bills passed by Congress. His secretaries serve as liaisons with Congress but are answerable to him, not to Congress. He nominates judges and appoints many federal officials. He can propose a budget to Congress and is responsible for the expenditure of federal funds appropriated by Congress. Once elected, the president is not dependent on Congress for his tenure in office, except in extraordinary circumstances. The great difference, of course, between the American president and the British monarch as envisioned by the founders is that the president is elected for a fixed term, whereas the British monarch receives his office by inheritance and serves for life.
The evolution of the British monarchy has concealed the close similarities that once existed between that office and the U.S. presidency, and this raises further questions. Has the United States been well served by essentially maintaining the constitutional position of the president as an avatar of George III? On those occasions when we have really needed to remove a sitting president, we have faced an impasse because the president is also head of state—a situation especially acute when there is a “mad king,” as in George’s later reign and, arguably, in the last presidential administration. Americans like to pride themselves that their head of state is elected and not hereditary, but that has not prevented most of our presidents from being mediocre at best (several truly awful), with only a handful of real leaders. So, too, with British monarchs and prime ministers in a parliamentary system, but the former now do less damage and the latter are more easily replaced.
It is unlikely that the United States will move away from a presidential system to adopt a parliamentary system with a ceremonial head of state and a separate, effective head of government. But we have seen in our country, especially in recent years, the problems associated with having both offices united in one person who is almost impossible to remove from power. It is not clear, short of rewriting the Second Article of the Constitution, how these problems could be addressed. Could the vice president, so clearly underutilized and already a part of Congress, undertake more prime-ministerial responsibilities in managing the president’s business there (and perhaps be elected separately from the president)?
For now, the coronation of King Charles III will give us Americans the opportunity to ponder, and perhaps to envy, the ways in which the British monarchy has evolved over time, unlike our own head of government.
