Martin A. Schain New York University Presented at THE EUROPEAN UNION STUDIES CENTER

1. LOOKING AT THE IMMIGRATION DEBATE IN COMPARATIVE PERSPECTIVE: How do we explain transatlantic differences? Martin A. Schain New York University Presented at THE EUROPEAN UNION STUDIES CENTER THE GRADUATE CENTER, CUNY April 14, 2011

2. The debate • US • Focus on illegal immigration and border control • Almost no focus on legal immigration and criteria for entry • Very little consideration of problems of integration • Europe • Strong focus on immigration and entry • Integration • Challenge to identity in Europe

3. Core question • Why are policies of immigration so different in the United States and Europe? • Indeed: why have they often been so different?

4. Table 1 Immigration Policies in France, Britain and the United States

5. Key to difference is politics and politicization • Politics • Whether issue is politicized: salience • Immigration not always politicized among political parties • Politicized • The way that it is politicized: framing • Immigration issue framed in different ways at different times

6. Table 2Politicization: framing immigration

7. Framing and Policy: Three dominant frames • Identity frame: immigration as challenge to national identity • related to immigration restriction • Electoral resource frame: immigrants as potential voters • related to more open policy • Labor-market frame: need for labor • can lead to both

8. In French case • Relatively open policies until late 1960s, driven by labor-market frame • but shift, even before 1974, to ID • Shift to restriction 1974 in context of shift in labor-market needs

9. British case • Before 1962—conflicting identity framing: Empire vs. aliens • Changed after 1962 with reframing of ID to “little England”

10. United States • Tension between identity and labor-market: ID at state level • Early framing of immigration issue as ID by extreme right: American Party: 1854-1860 • Then anti-Chinese movement in California—first restrictionist success in Washington: 1882 • Effectively countered by labor-market population policy at national level---until 1870s • Exclusionary policies—framed in terms of ID— against Europeans by 20th Century • Front door exclusion (ID); back door open (labor) • Electoral resource frame gradually gained domination after WWII • Weaker frame of illegality/identity

11. Dynamics driving different frames • How can we understand change? • Always alternative frames—driven by alternative actors • France: • Balance of national labor needs and national identity • But always advocates of challenges to national ID • Balance changed with arrival of large North African population • Solidified by rise of National Front and party salience • Increased salience of integration: immigration issue =integration

12. Britain • Until end of 20th Century, UK, country of emigration • Breakdown of Empire-Commonwealth ID consensus – reaction to real NCW immigration • Party shift: • Shift in Tory elites away from Empire • Labour never strongly supportive of immigration • Solidified by consensus on anti-discrimination, linked to multiculturalism • immigration issue=integration • More difficult in Britain, compared to France

13. United States • racist-ID framing of immigration issue weakened by civil rights movement • Electoral dynamic that grew out of structure of presidential politics • Movement towards immigrants as political resource– created electoral dynamic that grew • integration less salient in “nation of nations”

14. But why did US-type electoral resource shift not take place in Europe? • Bias of US presidential system • Differences in pol process—esp party dynamics • Strong political party structures limit access in UK and France— Compared with weak and penetrable parties in the US. • Distribution of immigrant vote reduces incentive in France and UK compared with US • Electoral constituencies: number and distribution

15. Table 3 Electoral weight Legislative Constituencies with 10 Percent or more “Immigrant Populations” (1998-2001)

16. Immigrant representation • Best in US by most measures, but • Limiting case of The Netherlands • Representation and cooptation • Vs. Representation and policy impact

17. Table 4 Policy influence Political Integration of Immigrant Populations, 2004/2007

18. Consequence of lack of political weight and influence • Enabled European parties to develop alternative electoral dynamic: immigrants as challenge, vs. resource

19. Framing leads in two very different, self sustaining directions • US focus on election resource leads to policies related to electoral success—limits ID dynamics • European focus on identity leads to more restrictive policies

20. And to different ways of understanding success • ID focus on expectations of policy success in developing integration– difficult to achieve: • “…the misconception that the liberal state should demand more of its immigrants than learning the language of the country and accepting the principles of its constitution” –an ethnic understanding defined by religion. (Habermas/NYT) • “All immigration tends to erode and destabilize national cultures that have shaped and comforted people for centuries, and it does so no matter who is doing the moving. Islam is different in the way that it disrupts European cultural norms and raises deep questions of assimilability.” (Caldwell) • Electoral Resource frame creates dynamic of openness, easier to achieve.