ABSTRACT

Attached as Appendix A is a comparative summary of the German, French, British constitutional systems, with special attention to the relationship between executive and legislative power, methods of election, and procedures for fixing accountability and breaking deadlocks. The British, French and Irish systems require a government to resign if it loses a vote of confidence, and the German system does so if, after voting in favor of a no confidence motion, the Bundestag is able to elect a different chancellor. In the British, German and Irish systems, the executive is elected by the legislature, and there is no legislative-executive balance to shift. The German system includes an interesting feature that helps to build party consciousness and legislative cohesion, and that might perform a similar function in the American system. As in the German system, constituency candidates could also be included on the party lists and could fill one of their party's at-large seats if defeated in the constituency election.