In April, The Economist argued, disturbingly, that the first 100 days of President Donald Trump’s second term may have been the most consequential of any president in almost 100 years, since the time of Franklin D Roosevelt. This theme was further emphasized by the cover headline, which reminded us that there were “Only 1,361 days to go.”
The then-British prime minister, Liz Truss, elected in September 2022, set sail brandishing a similarly radical economic agenda, which also sent stock and bond markets into a tailspin. Before the end of October, 49 days later, she was prime minister no more.
What can explain the starkly different outcomes in these two primary Anglophone Western democracies? In one, a prime minister famously proved to have a shorter shelf life than an average lettuce, while in the other, the president is locked in until early 2029.
In fact, the differing constitutional provisions that have fundamentally shaped these outcomes all trace their source to the American Revolutionary War of 1775 to 1783.
In 1763, Britain won the Seven Years’ War against France but at considerable financial cost. Major fighting in that war occurred in North America. Britain began imposing new taxes, including in its North American colonies, to help fix its adverse financial position. Armed resistance to these and other measures followed, leading to the American Revolutionary War. The British were largely defeated by 1781, and the Treaty of Paris in 1783 confirmed the independence of what was to become the United States of America.
After significant debate, the terms of the new US Constitution were agreed, and it was ratified in 1788. This was both a radical constitution and a significantly derivative constitution.
It was radical in the sense that it created a new, independent nation-state under an agreed, written, paramount document. It was derivative in the sense that its written structure replicated certain fundamental provisions of the unwritten British constitution that applied in 1788 during the reign of King George III.
This unwritten British constitution embodied a paramount executive government, ultimately led by the king, where other elite people, including the prime minister, drawn from the parliament, became members of his government. The parliament in Westminster retained its primary, separate function of enacting the laws which applied in Britain and across the British Empire. Combined with these two fundamental bases of political power was Britain’s independent judiciary, headed by the House of Lords and the Judicial Committee of the Privy Council.
After significant debate, the terms of the new US Constitution were agreed, and it was ratified in 1788. This was both a radical constitution and a significantly derivative constitution
This, then, was the basic model for the system of separate powers embodied in the US Constitution of 1788 that applies to this day. No new monarchy was created, of course, but the constitution did create a distinct executive government, outside of the legislature, headed by the president. Furthermore, America’s new parliament, the bicameral US Congress, was established as a separate lawmaking body and the new US Supreme Court headed the independent American judicial system.
Most importantly, the presidential term of office was stipulated in the constitution: Article II, Section 1, Clause 1 states that the executive power shall be vested in a president, who “shall hold his office during the term of four years”.
The US Constitution is also extremely difficult to amend. The raft of changes made after the conclusion of the American Civil War is the exception that confirms this adamant rule.
America’s famous Bill of Rights was ratified in 1791. In the late 18th century this document primarily protected the rights of substantial property-owning men, including the right to own slaves.
Many in the UK came to regard George III as being significantly responsible for Britain’s loss of its American colonies. The king, as can be seen above, did not enjoy absolute governing power. He was, accordingly, referred to as a “constitutional monarch”. But he remained the ultimate, active head of government. George III did not die until 1820 after almost 60 years on the throne (he remains Britain’s longest reigning king).
Following his death, and still bearing in mind Britain’s loss in the American Revolutionary War, the move to transfer virtually all remaining political power from the monarchy to the parliament at Westminster intensified. By the time Queen Victoria came to the throne in 1837, this transfer was largely completed.
The now radically revised — but still unwritten — British constitution stipulated, using extremely powerful “constitutional conventions” that, first, the seat of Britain’s executive government would henceforth be within the British parliament. Second, that the government would be headed by the prime minister, who along with all other ministers, must be members of the British parliament. Third, only a prime minister who could command consistent majority support in the lower house, the House of Commons, could retain government.
Both the US and the UK have democratic systems that have long been significantly dominated by two main parties, which have taken turns being in power — as a result of election outcomes. However, under the revised British constitutional system, which has now been in place for almost 200 years, each governing party has enjoyed greatly enhanced power — but also far more direct accountability, compared to the US, as a result of the government being entirely embedded within the parliament under the operating principles of what is now known as “parliamentary democracy”.
This system of parliamentary government was developed after Britian’s unhappy experience with the George III governance structure (significantly copied by the US). The new system was designed to remedy the worst flaws of that earlier structure by replacing it with a more modern and responsive system. While hardly flawless, it has stood the test of time.
Liz Truss was elected to lead the Conservative Party and became prime minister of the UK on Sept 6, 2022. She swiftly introduced what David Runciman in The Guardian called a “botched emergency budget”. This growth plan caused havoc in the bond market and sent the pound into a tailspin; the US dollar and the pound were almost at parity. The Economist called her mini-budget a disaster. Within less than 50 days she had lost the confidence of the parliament, the public and, most significantly, her own Conservative Party. She was swiftly forced to resign as prime minister.
Meanwhile, across the Atlantic, Donald Trump seems able to defy political gravity no matter how damaging his policy decisions are and how deeply compromised is his behavior.
A few days after the Trump administration introduced its extraordinary tariff plan on April 2, The Economist argued that, thanks to this, “market carnage has gone global”. Most mainstream Western media outlets forcefully echoed this view, combined with a massive surge in warnings about the threat of inflation, shortages and recession prompted by this recklessly dangerous policy initiative.
President Trump blinked and made some anxious adjustments, but within no time he had moved on to embrace the idea of accepting a $400 million gift for his presidential use of a hugely luxurious Boeing 747 aircraft, from the government of Qatar.
As the Truss example shows, it is almost unthinkable that a primary leader replicating this level of damaging and outrageous behavior in the UK could survive and thrive, as President Trump manages to do in America. They would, in Britain, almost certainly find themselves rapidly walking the political plank.
President Trump, however, looks as safe as can be in the White House, until early 2029, because America’s antique constitution, drafted many decades before parliamentary government was fully developed in the UK, rigidly locks in his exceptional security of tenure.
The author is an adjunct professor in the Faculty of Law, the University of Hong Kong.
The views do not necessarily reflect those of China Daily.
