Michael Minkenberg Tel. +49 (335) 5534-2257 Europa ... · 4.1, p. 50; Schmidt, 2000, Table 14, pp....

Michael Minkenberg Tel. +49 (335) 5534-2257

Professor für Politikwissenschaft Fax. +49 (335) 5534-2280

Europa-Universität Viadrina [email protected] Postfach 1786 http://politik.euv-frankfurt-o.de

D-15207 Frankfurt (Oder)

GERMANY

and

"Europa Fellows Program"

Collegium Polonicum

ulica Kosciuszki 1

PL 69-100 Slubice

POLAND

Paper for the ECPR 32

nd

h Joint Session of Workshops, Uppsala, 13-18 April, 2004, Workshop 16,

“Who makes immigration policy?” directed by Virginie Guiraudon, and Gallya Lahav.

Religious Effects on the Shaping of Immigration Policy in Western Democracies

Abstract. The growing debate in Europe about crucifixes and head scarves in public school classrooms

and the post-9/11 controversies about the compatibility of Islam and democracy within and beyond

Europe indicate the coming of a major new conflict area in Western politics, including the realm of

public policies. However, in conventional public policy research, religion has been largely neglected

as a relevant input factor and with the exception of a few welfare and social policy studies, there is

little knowledge and empirical evidence for its policy implications.

This paper starts with the observation of an ongoing and in some respects increasing significance of

religion in the politics of Western democracies and links it to processes of pluralization and

globalization, which in turn are related to migration moves across the world. It raises the issue how the

growing complexity and cultural diversity of Western countries in the face of new immigration waves

affects the functioning of democracies and in particular the politics of immigration control. The paper

shows a considerable diversity in immigration policies in the West, not just between the “settler

countries” and the European countries. It also demonstrates that contrary to some claims in the

literature, standard models of comparative public policy research cannot convincingly account for this

diversity and suggests to add religion as another factor. As a general conclusion, a modified “families

of nations” concept (F. Castles) may be an appropriate frame of analysis. This concept should adjust

for the interplay of nation-building, religious traditions, and institutional management of cultural

diversity.

The author thanks Susana Galán, Stefan Redlich, Miriam Schader, Katharina Stankiewicz, and

Franziska Zeisig (all Europa-Universität Viadrina Frankfurt/O) for their help in researching

immigration and integration policies.

mailto:[email protected]

http://www.euv-frankfurt-o.de/

Minkenberg: Religious Effects on Immigration Policies (March 22, 2004) 1

Introduction

The growing debate in Europe about crucifixes and head scarves in public school classrooms

and the post-9/11 controversies about the compatibility of Islam and democracy within and

beyond Europe indicate the coming of a major new conflict area in Western politics, including

the realm of public policies. However, in conventional public policy research, religion has

been largely neglected as a relevant input factor and with the exception of a few welfare and

social policy studies, there is little knowledge and empirical evidence for its policy

implications. This is even more astounding in the field of the comparative politics of

immigration and integration in liberal democracies and the resulting fundamental questions

regarding the management of cultural pluralism, which to a large extent stems from

immigration and growing immigrant communities in Western societies.

This paper addresses these issues from a dual perspective, as a comparative study of

religion and politics and a comparative public policy analysis. At the intersection of these two

perspectives lie the very topic of the ECPR workshop: immigration and integration policies.

Therefore, an attempt is made to take a closer look at the religious underpinnings of

immigration and immigration control, as a first step towards a larger assessment of the

interplay of religious and political factors in the comparative politics of multiculturalism. As

Tomas Hammar reminds us, citizenship in the pre-modern past was closely connected to

religion and modern citizenship can be seen as one of the results of secularization (Hammar

1990: 49-51). Still today, some countries like Greece link citizenship to membership in the

Greek Orthodox state church. And the well known argument by Rogers Brubaker (1992)

about the role of “cultural idioms” for citizenship can also be linked to religious components

of cultural and national identities. Finally, the current debates of Muslim integration in

Western democracies or Turkey’s status as a membership candidate for the EU most vividly

illustrate how religious arguments draw distinct dividing lines of access and membership.

In general, therefore, we should expect religious legacies to somehow inform modern

concepts of membership in political communities. Hence, one of the central questions of this

paper is: does variation in the politics of immigration and integration correlate with cultural

and religious variations, and to what extent can it be attributed to these differences within the

world of Western democracies? More specifically and in line with the framework essay for

this workshop, we may ask whether particular religious traditions and institutions provide

constraints for a more liberal immigration and integration policy. For example, a recent study

of religious freedom and pluralism in transitional societies in Southern and Eastern Europe

found that “holistic visions” of society, as found in Christian Orthodoxy or Islam tend to


result in restrictions of minority rights (Anderson 2003: 195f.). In this light, one might

hypothesize that cultural heritage in Western democracies (i.e. Catholicism vs. Protestantism)

is a significant predictor for variation in immigration and integration policies, as has been

found for other policy areas as well (F. Castles 1998, see also below). This, however, needs to

be tested in comparison with other dimensions of the religious factor (for example, religiously

oriented political parties, degree of secularization etc.) and with other models of comparative

public policy research. In general, religion’s influence on public policy is culturally path-

dependent. Depending on the degree of secularization via church-going rates, one might

expect some kind of convergence. However, the confessional legacy is postulated to maintain

a policy effect beyond the actual church-going rates.

In order to manage the complexities of the issues at hand, several limitations will be

applied in this paper. First of all, the analysis follows the fundamental distinction made,

among others, by Hammar who in one of the first comparative studies of immigration policies

differentiates between politics of immigration control and immigrant policy. The first refers to

“the rules and procedures governing the selection and admission of foreign citizens”

(Hammar 1985: 7) and shall be at the core of the analysis, its major dependent variable. The

second involves “the conditions provided to resident immigrants” (ibid. p. 9). It includes

aspects of integration and management of cultural pluralism and shall be considered

marginally here and to a fuller extent at a later stage of analysis. Another limitation concerns

the concentration on policy output as opposed to policy outcomes (Almond/Powell 1978).

While the former refers to official governmental policies and legislation, the latter includes

the implementation of the policies and its societal consequences, for example immigration

rates or (xenophobic) reactions to certain laws or regulations. The relationship between

outputs and outcomes is at the heart of many studies of immigration and one of the core

meanings of the question whether politics matters. But here, it is of secondary importance, as

is the political discourse on immigration, which more often than not differs from official

policies.

There are two more limitations, one of time, another of space. The time frame for the

analysis comprises the period after World War II with regard to many factors such as

constitutional and institutional provisions, the role of political parties etc. But the dependent

variable of immigration policies has been specified and analyzed more narrowly for the

second half of the 1990s. While it is too complex to include issues of policy change from the

1970s to the 1990s and beyond 9/11 for all countries studied here, it is assumed that the

policies of the late 1990s reflect both longer-lasting policy patterns in each country and first


reactions to the changes of the late 1980s and early 1990s, when new problems in countries of

origin and the end of the Cold War led to a world-wide increase of migration moves

(Castles/Miller 2003: 80f.). Moreover, the data collection for immigration policies has been

done for the late 1990s in order not to include first reactions to 9/11, which should be

analyzed separately. Ideally, one would have to analyze immigration policies at several time

points (1950s., 1970s, 1990s and post 9/11) to detect patterns of policy shifts but there is an

obvious time and data collection problem.

The final limitation concerns space, more specifically the range of countries included.

Unlike most comparative studies of immigration policies, this paper claims to cover the entire

group of liberal democracies. While there is a lot to be gained from single-country or small-n

case studies, there are also many generalizations inferred from particular cases based only on

theoretical reasoning or sketchy evidence. This paper is an attempt to overcome these

limitations by broadening the (at the obvious expense of in-depth analysis of particular cases).

Nonetheless, not all democracies are included. As in previous analyses by the author (see

Minkenberg 2002), the selection of countries rests on a most similar systems design on a

global scale, the criteria of which being whether or not a country is a consolidated democracy

with a high ranking on a variety of democracy scales, has a Western or Latin Christian

religious heritage, and has reached a high level of socio-economic development, i.e., a Gross

National Product of at least $ 10,000 per capita in the late 1990s (see Lijphart, 1999, Table

4.1, p. 50; Schmidt, 2000, Table 14, pp. 418-423; Fischer Weltalmanach, 1999).

Consequently, countries like Greece and Japan are excluded, as are all newly democratized

countries in Central and Eastern Europe, and a group of 19 country cases is retained.

The paper is organized in five steps. First, a general overview is given for the

relationship between religion and politics and the role of migration. Second, a review of

comparative policy research is provided, with particular attention to the conceptualization of

religion in the functioning and outputs of democracy and to the field of immigration policies

therein. At the end, a conceptualization and operationalization of immigration policies for

comparative analysis is offered. Third, several standard models of public policy are discussed

with regard to variations in immigration policies. Forth, these models are contrasted with a

religiously oriented analysis and its interpretation. And fifth, some observations are added on

further findings concerning aspects of immigrant policies (integration) and multiculturalism.


Processes of pluralization and globalization: new challenges to the political regulation of

religion and the functioning of democracies

For a long time, the so-called “Western world” has been interpreted as undergoing a long-

term process of secularization or decline of religion, the replacement of religious values by

secular values. But the relationship between religion and politics in the modern world has

received increasing attention in everyday as well as social science discourse. Nonetheless,

some intriguing disparities exist between the renewed interest in religion and its treatment in

the social sciences. One can find, for example, a rather widespread neglect of religion as a

relevant factor in the field of political science, in contrast to legal scholarship and sociology.

The religious factor has played a marginal role and usually was dealt with narrowly in the

context of welfare state and electoral studies. Another discrepancy exists between the renewed

importance of religion in the Western world, and the accompanying attention paid to it, on the

one hand, and the persistence of a social science common sense, which assumes the

secularization of the Western world as a long-lasting, linear trend, meaning either the

privatization of religion, or even the decline or disappearance.

However, there is sufficient empirical evidence to demonstrate that religion, even in

the Western world, is a power that does not want to vanish (for the following, see also

Willems/Minkenberg 2003). First, many religious traditions experience the forming of

conservative or fundamentalist religious movements, even in established democracies, among

non-Christian and Christian traditions alike, not to mention developing countries (Bruce 2000;

Kepel, 1997; Marty/Appleby 1991; Minkenberg 1990). Second, to an alarming extent, the

number of violent conflicts and civil wars, which are religiously framed or motivated is on the

rise, most notably in India, Pakistan and Afghanistan, in Indonesia, in the Middle East, but

also closer to the European “home“ on the Balkans – and let us not forget Northern Ireland

where a long-time established democracy cannot turn the violent clash between Catholics and

Protestants into a peaceful conflict regulation (see Bruce 1986; Calic 1998; Eckert 2003).1

Another, more peaceful element of the return of religion into the realm of politics is

the increasing public role of established and non-mainline churches in many Western, and one

may include here also the Latin American, countries – a process, which José Casanova (1994)

calls the “deprivatization of religion”. Moreover, both Christian denominations and Islam are

1 Whether the North American case of the killings of abortion clinic personnel – in the last 10 years, seven

persons have been killed in the US and Canada in the name of religious values – deserves the label of a

religiously motivated civil war, deserves some clarification. There is sufficient evidence that there is a small and

militant group supporting the perpetrators (New York Times, Sep. 4, 2003).


undergoing global growth: Islam in Africa and Asia, but also in Western Europe, Catholicism

in Africa and Eastern Asia (S. Korea, China), Protestantism in Latin America, Eastern Europe

and East Asia. In many instances this is remarkable because these religious traditions prosper

in regions where they are historically “foreign”, are “imported” by migrants or promoted by

missionaries. Finally, one should also include the multitude of new sects, religious cults, and

small religious communities, although the spread of New Age, Buddhist and other cults in the

Western world are difficult to measure and to interpret (see Bruce 2002, chaps. 4, 6).

In Europe, more than anywhere else, many signs have pointed at a receding political

impact of organized religion since the 1960s, such as church attendance rates, the number of

priests per population, the participation of the young, the knowledge of the faiths (see Bruce

2002; Davie 2000). But even here, the pluralization and increasing heterogeneity of the

religious map leads to a growing number and intensity of conflicts at the intersection of

politics and religion. Let us consider a few examples. First, one of the most visible examples

is the immigration and growth of non-Christian minorities, in particular Muslims. They are at

the center of current controversies about multiculturalism, integration of ethnic and religious

minorities, and transnational identities (see Addi et al. 2003; Escudier, 2003;

Heitmeyer/Dollase 1996; Kastoryano 2002; Nielsen 1995, 2001; Vertovec/Peach 1997).

Second, we must not overlook those immigrant minorities, which have a Christian

background but of a rather different theological background of Eastern European Orthodoxy

or Christianity in the developing countries. Nor should we, thirdly, forget the increasing

number of atheists or unaffiliated. For example, in Germany, with the accession of the GDR

in 1990, the percentage of officially counted non-religious, or those not affiliated with any

church jumped from a few in the old Federal Republic to about 27% today (Fischer

Weltalmanach 1999: 163). They prompt new public debates on the regulation of the

relationship between religion and politics, not always with results in their favour. Finally, it is

the European integration process itself, which triggers new and heated discussions, such as the

issue of religious references in the preamble of the future constitution of the EU, or even more

vividly the debate whether Turkey, for religious and cultural reasons, belongs to Europe and

should be an EU member or not (see Robbers 2003). An overview of the current religious

complexity of Western societies is given in table 1.


Table 1: Religious Diversity in 19 Western Democracies (mid 1990s or most proximate year,

in per cent of resident population)

Protestant Catholic Jewish Muslim Orthodox Other

Austria 5 78 0.1 2 - 0.2

Australia 36.3 26.2 0.44 1.1 2.8 4.8

Belgium 0.4 88 0.35 2.48 - n.d.

Canada 30 45.7 1.2 0.9 0.9 8.8

Denmark 89 0.62 0.06 - - n.d.

Finland 86.6 - - - 1.1 n.d.

France 1.6 81 1.2 5.14 0.2 n.d.

Germany 34.1 33.4 0.04 3.7 0.6 0.7

Ireland 3.7 87.8 0.8 - - n.d.

Italy 0.09 90 0.05 1.24 - n.d.

Netherlands 26 36 0.19 3 - n.d.

New Zealand 38.5 13.8 - 0.4 - 13.4

Norway 89 0.83 - 0.5 - n.d.

Portugal 0.5 93 0.02 0.15 0.2 1.3

Spain 0.1 97.3 0.03 0.74 - 0.4

Sweden 91.7 1.7 0.19 0.9 1.17 0.03

Switzerland 40.1 46.3 0.26 2.2 1.04 0.42

United Kingdom 71.8 13.1 0.52 1.4 - 1.3

USA 29.6 26 2.6 1.8 1.5 0.19

Note: Countries in which Islam constitutes the third largest religious community are shaded grey,

countries in which Islam constitutes the second largest religious community are shaded grey and in

bold.

Sources: Fischer Weltalmanach (1999), various sources.

This survey shows that in more than half of the 19 democracies, or 58%, Islam constitutes

already the third or even second largest religious community. And the four countries, all

Western and Southern European, where Islam is the second religion, are all Catholic

countries. If there is a “Catholic way” of dealing with minorities or controlling access, there

should be noticeable differences between these and other democracies with large non-

Christian communities.

All these developments push in the same direction: the established institutional and

political arrangements to regulate the relationship between religion and politics in the

framework of liberal democracies, long seen to have been solved once and for all, are

challenged fundamentally and require new justifications. Accordingly, we see some major

shifts in the debate in two groups of Western democracies, the ones with a more or less

established church structure, and those with a more or less clear separation between church

and state.


The first group comprises countries like Great Britain or the Federal Republic of

Germany as well as the Scandinavian countries. Here, we witness increasingly conflictual

processes of realigning religion in the public sphere, for example with regard to the role of

religious education (an increasingly controversial topic in Germany), the presence of

headscarves and Christian symbols in the public space (see the Crucifix-sentence of the

German Constitutional Court of 1996or the current wave of legislation banning the headscarf

from public offices), the fight for religious freedom for non-Christian churches, for example

the debate in Great Britain regarding the recognition of Muslim communities and the torn

position of the established Church of England, or the steps towards disestablishment of the

state church in Sweden in 2000 (see Gustafsson 2003; Modood 1997).

But also in the second group, the countries with a more separationist regime, such as

the US and France (or Turkey), the established role of religion experiences increasing

pressures from actors who interpret the neutrality and indifference of the state in religious

matters particular political positions at the expense of religion. Secularism is seen not as a

guarantee for state neutrality and a balance between all religious forces, but as a political

program equivalent to a secularist state religion (see Kymlicka/Norman 2000; Wald 1992;

Watson 1997).2

But looking at these changes in religion and political activities of the religious

provides only one half of the picture on the changing nature of the relationship between

religion and politics. The other half is constituted by changes in politics itself. Since this

would be too large a topic to discuss thoroughly, a few significant aspects of the

transformation of the political should be mentioned: First, one major point is what has been

called the fundamental politicization of modern societies (see Greven 1999: 40-54). All

efforts of libertarian or other like-minded actors notwithstanding, there are only very few

social arenas left, which remain unaffected by political decisions and regulation. Second, this

goes along with a tendency of political centralization at the level of the nation state as well as

the supra-national level, e.g. the EU or the UN on the one hand, and with a tendency of

increasing complexities and interdependence of social phenomena on the other. This process

raises fundamental questions about the classical liberal concept of a separation of the public

and private spheres – a challenge, which has been brought forward already in the protest

movements of the 1960s, exemplified for example in the slogan of the women’s movement

2 A most recent example from the US is the case of the Alabama Supreme Court Justice who installed a

monument exhibiting the ten commandments in the hallway of the Court Building, arguing that this was a

reminder of the religious and biblical foundations on which the United States was built. He was ordered to

remove the monument but refused to do so. A Federal Court finally suspended him from office, and the

monument was removed (see New York Times, Aug. 23, 2003).


“the personal is the political” (see Casanova 1994, chap. 2; Geuss 2002; Rorty 1994; Shklar

1989: 24-31). Autonomous spheres of political action, as provided by federal or decentralized

political structures are thus undermined and constrained.

Third, the processes of technological progress and cultural pluralization, along with

the erosion of traditions and the concept of nature as the ultimate boundary of human action,

increase conflicts based on value judgments. Examples include the recognition of

discriminatory practices (which were seen as “normal” before), the regulation of reproductive

health and bio-medicine, genetical engineering in food production and others (see

Gottweis/Prainsack 2003). These are issue, which ultimately touch upon religious or value-

based orientations of many citizens, not just fringe groups, and provoke religiously motivated,

or framed, political intervention (see Heclo 2001: 9f.). Forth, the processes of globalization

are accompanied or facilitated, some argue constituted, by the changes in mass

communication and media networks, which provide venues for the diffusion of ideas, learning

and copying effects and new possibilities of overcoming the traditional constraints of time and

space. Again, we witness and continually expect lasting consequences for the activities of

religious actors – for example the formation of a trans-national Islam outside the Arab world

(Schiffauer 2003) – and the political reactions and regulations.

Finally, these developments in various parts of the world are accelerated by and

interwoven with economic and cultural globalization processes (see Haynes 1998; Robertson

1991, 2003). The weakening of state institutions and national identities by these processes,

which are even more dramatically highlighted by internal conflicts in the developing world,

result in an ideological vacuum. This provides an opportunity for religions traditions, or their

“re-inventions”, to gel into cores of cultural identities, projects of transnational unities and

loyalties – it is this scenario where Huntington’s argument of a “clash of civilization” unfolds

its most persuasive power (Huntington 1996; see also Barber 1996).

Democratic theory usually neglects the issue of religious values underlying the

functioning of political systems. However, Manfred Schmidt in his survey of democratic

theories states, if only in passing, that worldwide the vast majority of democracies (i.e. 79 of

88 which had been ranked as “free” according to Freedom House) were largely Christian. He

underlines that the difference between democratic and non-democratic regimes varies with the

proportion of Catholics and Protestants and concludes that democracy has roots in particular

in those countries, which are culturally shaped by Christian values (Schmidt 2000: 448).

Samuel Huntington goes a big step further in this direction. For him, religion defines the core

of civilizations, and historically religious boundaries denote the dividing lines of various


cultures. The close relationship between Christianity and democracy and the duality of secular

and sacred powers and spheres within the Christian world constitute, according to Huntington,

the concept of “the West”. It is the separation of church and state, as found in the Christian

civilization, which Huntington identifies as the prerequisite for the emergence of modern

democracy (Huntington 1996: 70). In contrast, other religions provide almost insurmountable

problems for democratization. In Confucianism, Cesar is God, in Islam God is Cesar, and in

orthodox Christianity, God is Cesar’s junior partner. The problem for democracy is not

confined to the existence of extremist groups like Muslim fundamentalists. “The underlying

problem for the West is not Islamic fundamentalism. It is Islam” (ibid.: 217).

This position has been criticized lately by some democratic theorists like Alfred

Stepan (2000). Stepan does not see a necessary constrast between non-Christian traditions and

the values and institutions of modern democracy and points out, that even in the West,

democracy was established against fierce opposition especially among religious forces such as

the Catholic church. Not unlike Michael Walzer (1998) and Veit Bader (1999), Stepan

emphasizes a “priority for democracy” over secularism. But he adds that democracy, in the

face of religious interests and traditions, must be constrained by “twin tolerations”. By this he

means that, on the one hand, democratic institutions must be free to generate any policies

within the framework of constitutional democracy and human rights. Hence, there should be

no constitutionally or otherwise guaranteed privileges of particular religious bodies to certain

politics. On the other hand, the democratic state must guarantee free religious exercise in the

private sphere as well the opportunity for religious groups to promote their values in the

public (ibid., 39). This includes the possibility of religious groups to form political parties and

does not prescribe any particular arrangement of chuch-state relations (see below and

Minkenberg 2003a, b).

Against Huntington, Stepan argues that the “clash of civilizations” thesis ignores the

historically contingent processes, which constitute a compatibility between any religious

system and democracy (see also Willems/Minkenberg 2003: 15f.). For example, recent

studies in Central Asia documented the religiously devout Muslims are more supportive of

democratic institutions than those whose religiosity was less pronounced (see Rose 2002). It

is to be seen if it is not political and cultural factors, rather than religious ones, which

contribute to the difficult relationship between Islam and (democratic) modernity: “The

politics of Islam is complicated by geopolitical forces, and by nationalistic and anti-colonial

sentiments among many political activists. [...] If Islam was the dominant religion in Europe

while Catholicism dominated in the Middle East, we might instead be pondering the special


case of Catholicism instead of Islam.“ (Jelen/Wilcox 2002: 321). Hence, Stepan calls the idea

that Christianity is a functional prerequisite of democracy a „fallacy of unique founding

conditions“ (Stepan 2000: 44). The historical emergence of a particular social and political

phenomenon – here the separation of church and state in the Western world – should not be

confused with the possibility of its re-emergence or reformulation under different

circumstances.

Shifts in Comparative Public Policy Research and the Absence of Immigration Policy

Research

The emphasis on the Christian legacy for modern democracies in the mainstream literature on

democracy and democratization (the view “from without”) is mirrored by the emphasis on the

irrelevance or declining relevance of religion for the output of democratic systems (the view

“from within”). In fact, most comparative public policy literature ignores religious or cultural

variables and tends to concentrate instead on the question of whether politics or economics

matter (see Nelson, 1998: 574-577). Two large traditions stand out. One is the group of

modernization theorists who argue that socio-economic modernization brings about a

convergence in policy outputs. In this view, religion matters only to the degree that its

doctrines are reflected in party platforms, or the general difference between Social

Democratic and Christian Democratic parties (see Wilensky 2002). The other group consists

of democratic theorists and party researchers who argue it is primarily structures like

corporatism and the institutional set-up of democratic regimes that matter for the output (see

Lijphart 1999). The long-lasting debate whether parties matter has not been decided.

But if politics is understood, in David Easton’s famous phrase, as “authoritative

allocations of values” (Easton 1965: 24), these values clearly include more than goods and

services as measured in public expenditures. So far the literature’s usual focus on quantifiable

policy outputs often leads to the ignoring of a wide realm of government action and outputs

that shape society as much as spending levels. This includes quality of life issues and related

policies, such as education policy, abortion and other aspects of family policy, gender issues

and – strikingly – also immigration policies, which only recently have attracted some

attention in the comparative policy literature – not in the least because in the context of

advanced industrial democracy, personal concerns are increasingly public, and thus public

policy, concerns (see F. Castles 1998: 248).


A few major policy studies include religion, but then only marginally, and not in a

manner that differentiates between various manifestations of religion. For example, Gøsta

Esping-Andersen (1990) distinguishes three welfare state regimes that roughly correspond

with Protestant and Catholic traditions, i.e., the liberal regimes of the successor states of the

British empire, the conservative regimes of Continental Western Europe, and the social-

democratic regimes of Scandinavia. But in his empirical analyses the religious factor appears

only in terms of the existence of a Catholic party. In contrast, Kees van Kersbergen (1995)

focuses on one type of welfare state only and analyzes the influence of Christian Democratic

parties and traditions.

Francis Castles takes these approaches one step further in his “families of nations”

concept (F. Castles 1993, 1998). He recognizes that “since religion defines both the cultural

appropriateness of beliefs and behavior, religious differences are clearly relevant to policies

concerning education and personal conduct” (F. Castles 1998: 53). But these “religious

differences” are identified only by a narrow range of variables: Christian Democratic

incumbency, Catholicism, and Catholic cultural impact, the last being a dichotomous

summary measure of the first two. But this operationalization is problematic because France,

Germany, and Greece, along with Italy and Austria, belong to the category of nations with a

Catholic cultural impact.

In general, the current state of the research reveals two types of comparative policy

analysis: On the one hand, a broad comparative scope is coupled with a weak

operationalization of the religious factor. On the other hand, a more nuanced treatment of

religion, usually focusing on the confessional patterns and the interaction between churches

and other political actors, is coupled with a narrow scope of comparison. And in none of these

comparative studies of public policy, immigration and integration policies figure as prominent

examples. In light of the aforementioned global trends and theoretical discussions, this is a

peculiar negligence. In order to situate comparative immigration policy research into the

larger field, it is worth remembering that Gabriel Almond and G. Bingham Powell distinguish

four kinds of public policies, i.e. (a) policies of extraction, (b) policies of distribution, (c)

policies of regulation and (d) symbolic policies (see Almond/Powell 1978: 283-314, 1992:

107-115). The former two largely involve money in terms of taxation and spending. It is the

third type, “the exercise of control by a political system over the behavior of individuals and

groups in the society” (ibid., p. 113), along with the forth, which is of special interest here. To

a large extent, immigration and integration policies belong to this type. And many of the

domains that Almond and Powell attribute to the type of regulatory policies such as family


relations, personal conduct, protection of the person and religious activities (see idem 1978:

309) belonged historically, at least in Europe, to the domain of the churches instead of the

state. This mirrors the fact that historically, citizenship was based on membership in particular

religious communities (see above).

The Comparative Study of Immigration Policies: Towards an Operationalization

In line with the previous chapter, the comparative study of immigration and integration

policies should be tied to the more general comparative public policy discourse and models,

and it should include the analysis of religious, or more broadly cultural, factors as possible

constraints or enablers of particular policies. An obvious problem for such an undertaking lies

in the absence of any systematic and comparable data on immigration policies in the Western

world. While there is no shortage of medium-to-large N comparative data in the areas of

economic and political development and related policies (eg. F. Castles 1998; Lijphart 1999;

Wilensky 2002), the comparative analysis of immigration policies usually rests on a non-

systematic and cursory use of many countries or a limited set of country cases (see e.g.

Baldwin-Edwards/Schain 1994; Cornelius et al. 1994; Joppke 1999; Hammar 1985; Hollifield

1992).

Some might argue that on a global scale, differences in immigration policies are

fading, at least among Western democracies, due to processes of globalization and the

emergence of transnational actors and approaches, particularly in the context of European

integration and harmonization (see Soysal 1994; Geddes 1999). This would render a

comparative analysis among Western states obsolete. But the paper holds that despite some

processes of convergence and like reactions of Western nations to new waves of immigration

and despite the influence of the EU on member states regulations, nation states still remain the

principal actors in establishing boundaries of territory and citizenship and controlling access

(Hollifield 1997, 1998; Joppke 1999; Thränhardt 2003). So far, only a few projects have

attempted to collect in a systematic manner data on immigration and integration policies or

aspects thereof on a large or even world-wide scale, which are useful for such comparisons.

Among these, the “Comparative Citizen Project” deserves special mentioning because here,

over a number of years a large group of scholars have collaborated in systematically

categorizing and collecting data on citizenship (Aleinikoff/Klusmeyer 2000, 2001, 2002; Weil

2001). For the analysis at hand, this data collection provides an excellent resource.


In order to measure the degree of openness of particular immigration policies and to

compare them for all democracies, a scale of immigration policies is constructed based on

some criteria and data of the “Comparative Citizenship Project” and of other literature.

Following the distinction between immigration policies and integration policies made above,

the emphasis is on the former only, and models of integration and multiculturalism are

postponed for research at a later stage (for this, see Enzinger 2000; Hollifield 1997). Next to

the data collection problem, the selection of relevant criteria for the classification of

immigration policies is also hampered by a high degree of complexity and the widespread

existence of national idiosyncracies (see Heinelt 1994: 10f.). As a starting point, the core

aspect of any immigration policy rests in the attempt to control access and membership and

this is reflected in most of the comparative literature (see e.g. Cornelius et al. 1994). But

Tomas Hammar rightly stresses that immigration policy basically comprises two dimensions,

control of admission (from strict to liberal) and guarantees of permanent status (from secure

to vulnerable) (Hammar 1985: 9; see also Thränhardt 2003: 21-27). The paper follows this

reasoning and translates it into four basic categories with three values each, ranging from

restricted (0 points) to open (2 points): the existence of ius soli (from unconditional to non-

existent), the requirements for naturalization (from restrictive to easy and fast), the logic for

the selection of immigrants (from zero-immigration with the possibility of a guest-worker

system and/or ethnic quota to a general openness with point system), and the modes of family

reunification (from restricted to easy) (see also Hammar 1985: chap. 9).3 In this, the third

category (selection of immigrants) seems most problematic because of the various dimensions

(and exceptions to the rules) involved. For example, ethnic quotas for Germans may seem an

equivalent to post-colonial immigration in other countries. But because of the ethnic

restriction (however lax in practice) and the underlying ideology of an ethnic people (the logic

of a “homecoming”), it is clearly more restricted than a “colour-blind” admission of citizens

from former or existing colonies. Post-colonial admission policies are therefore rated as in-

between an ethnic quota approach and a more open point-system. Moreover, the European

dimension, although far from a uniform standard of immigration policies among EU member

states, eases some of the restrictions in labor migration as a result of the principle of free

movement. Therefore, all other things equal, EU membership results in an “upgrading” by 0.5

of the rating in the selection category. This does not apply, however, to the family unification

3 One could add another category, that of admission of asylum seekers and refugees, which especially in

Germany has functioned as a major avenue of de facto immigration (Joppke 1999: 85; see also Minkenberg

2003c). But when it comes to the issue of policies, asylum policies constitute another type of admission control

which should be treated separately.


category because the EU directive on family unification was issued after the time frame for

the selection of data. This is also true for the new German nationality code of 2000, which

does not inform the points Germany receives. This procedure results in a distribution of the 19

countries under consideration from very restricted immigration policies in Austria and

Norway to very open policies in Australia and Canada. These results are summarized in table

2.

Table 2: A Typology of Immigration Policies

Restrictive

Moderate

Open

Austria

Norway

Denmark

Switzerland

Germany

Finland

Portugal

Italy

Belgium

Spain

Great Britain

Ireland

France

Sweden

Netherlands

New Zealand

USA

Australia

Canada

Restrictive <--------------------------------------------------------------------------------------------> Open

0 0.5 1 1.5 2 2.5 3 3.5 4 4.5 5 5.5 6 6.5 7 7.5 8

A,

N

CH,

DK

D,

FIN

P, I SP B GB,

IRE

F,

SW

NZ,

USA

NL AUS,

CND

Note: For details see appendix I.

Sources: Author’s research (see appendix I)

The distribution of countries in table 2 reflects by and large the classification of countries in

much of the comparative literature, with the settler countries (Australia, Canada, New

Zealand, and the United States) on one end of the scale, and central and northern European

countries on the other. In the middle range, there appears a mix of a Mediterranean type and

the British Isles. Great Britain and Ireland receive the same number of points but for rather

different reasons (see appendix I). The following chapters turn to the question of what lies

behind these grouping of countries, in light of the standard models of comparative public

policy research and some other accounts.

An Analysis of Immigration Policies – Standard Models of Comparative Public Policy

To the extent that immigration policies are analyzed comparatively, the lines of research

usually follow the paths mentioned before, i.e. socio-economic and political models. Among


the first comprehensive attempts to develop an analytical framework for the comparative

studies of immigration policies is Tomas Hammar’s project which dates back to the times

before the new wave of global migration (Hammar 1985). He distinguishes between

“economy” and “ideology” as driving factors behind immigration policies, i.e. labor market

and nationalistic concerns, which he sees responsible for the opening and closing of the

borders to migrants towards particular groups and during particular times (for example before

and after the energy crisis of 1974, towards refugees from the Soviet bloc as opposed to other

refugees). In line with this reasoning and the socio-economic modernization argument in the

public policy literature, one might postulate that the openness of immigration policies varies

with the extent of socio-economic modernization and related labor-market needs (see Heinelt

1994: 12-14; Wilensky 2002). Table 3 groups the countries according to their scores on a

modernization scale, measured by several indicators of economic performance (growth,

inflation, unemployment) in two periods (1985-89, 1990-96) and averaged for the entire

period (see Wilensky 2002: chap. 12)

Table 3: Modernization – Economic Performance (1980s and 90s) and Immigration Policies

Restrictive

Medium

Open

Low (Scores 1 and 2)

Great Britain

Italy

Canada

France

Medium (Score 3)

Denmark

Finland

Germany

(Portugal)

(Spain)

Australia

Netherlands

New Zealand

Sweden

High (Scores 4 and 5)

Austria

Switzerland

Norway

Belgium

Ireland

USA

Note: Portugal and Spain are missing in Wilensky’s analysis

Source: Author’s research and Wilensky (2002: 444)

Table 3 suggests no particular relationship between level of socio-economic modernization

and immigration policies. If anything, the relationship is inverse because with the notable

exception of the United States the countries with a consistently high economic performance in

the two periods cluster in the groups with restricted and moderate immigration policies. On

the other hand, countries with a consistently low economic performance tend to have more

open policies. Germany is an interesting case because it moved from a high level of economic


performance in the 1980 to a low level after (and as a consequence of ) unification but the

immigration policies turned slightly more open during the 1990s.

Another economically oriented model emphasizes the close relationship between

welfare state regimes and immigration policies. In fact, this model occupies a prominent place

in the comparative immigration literature. It has been suggested that there is a clear-cut

symmetry between typologies of welfare states and typologies of immigration and integration

regimes (Faist 1998: 151; see also Baldwin-Edwards 1992; Bommes 1999: 177-194, and S.

Castles 1998). This line of reasoning largely follows Esping-Andersen’s categorization of

welfare state regimes according to the arrangements between state, market and the family and

in particular the degree of “de-commodification” of labor, i.e. the extent to which welfare

entitlements are seen as social rights (“social citizenship”) and allow subsistence and a status

of the individual independent of the labor market (Esping-Andersen 1990: 21). According to

this view, the ensuing “three worlds” of liberal, conservative-corporatist and socialist or

social-democratic welfare state regimes translate directly into the modes of immigration

control. Whereas liberal welfare regimes allow a certain opening of their borders and market-

oriented regulation of immigration flows, the conservative model would result in a more

restricted, tightly regulated approach. In-between one would find the socialist model of a

rather tightly controlled but more egalitarian approach.

Table 4, which summarizes welfare regimes and immigration policies for the 19

countries, does not support the argument of a precise symmetry between the two. Instead, we

find a centripetal tendency among conservative welfare states, with Austria and Germany

straying into the restrictive immigration policy group and France going into the opposite

direction. The special case of France in this regard is underlined by the fact that the country

also deviates from the conservative welfare states when it comes to family policies and

gender-related issues – in both areas of immigration and family policies it stands as the

opposite to Germany (see Minkenberg 2003b). Quite interestingly, the socialist welfare state

group tends to polarize into a Scandinavian group (without Sweden) which applies tight

controls and a mixed group of a likewise egalitarian approach which tends to be rather open to

immigrants. Hence it is misleading to treat both conservative and socialist welfare regimes as

“closed systems” which draw strict boundaries between the beneficiaries of their regimes

(citizens) and the “rest of the world” (see Freeman 1986: 52ff.). The only congruence with the

argument is found among the liberal welfare states (with the exception of Switzerland). In

these countries, we find a consistent market orientation. Great Britain does not obscure the

picture because according to Esping-Andersen’s rating, it falls equally into the liberal and the


socialist camp of welfare states and cannot count as a clear-cut case of a liberal welfare

regime.

Table 4:Welfare Regimes and Immigration Policies

Restrictive

Moderate

Open

Conservative-

Continental (max 8)

Austria (8)

Germany (8)

Belgium (8)

Ireland (4)

Italy (8)

(Portugal)

(Spain)

France (8)

Socialist (max 8)

Denmark (8)

Finland (6)

Norway (8)

Netherlands (6)

New Zealand (4)

Sweden (8)

Liberal (max 12)

Switzerland (12)

Great Britain (6)

Australia (10)

Canada (12)

USA (12)

Note: The attribution of country scores relates to the scores each country received in the respective

welfare type where it scored the highest proportion of points.

Problematic cases are Finland (6 of max8 in socialist scores, 6 of max8 in conservative scores) and

Great Britain (4 of max8 in socialist scores, 6 of max12 in liberal scores),

Spain and Portugal are missing in Esping-Andersen’s typology

Source: Author’s research and Esping-Andersen (1990: 74)

A similar distribution is found when applying models of political economy, measured by

degree of corporatism (Wilensky 2002: 118). Among the six least corporatist countries,

Australia, Canada, New Zealand and the USA exhibit open immigration policies, and Great

Britain and Ireland moderate policies. But the corporatist countries spread more or less evenly

across the spectrum. Only when the partisan factor (left-wing vs. Catholic party governments)

is introduced, do some effects appear. Among the four Scandinavian countries, which are

considered left-corporatist, Denmark, Finland and Norway employ restrictive immigration

policies, with Sweden being a grand exception.

Hence, it might be more promising to look at more political factors. One of the most

influential lines of argument on divergence in policy output focuses on type of democracy. A

prominent model is Arend Lijphart’s distinction between majoritarian and consensual

democracies, distinguished by the degree to which political power is centralized and

uninhibited by checks and balances (Lijphart 1999; see also Schmidt 2000, chap. 3.3). In

majoritarian democracies, the parliamentary majority and the executive, which emerges from

it, encounter few constraints on their exercise of power. In consensus democracies, on the

other hand, the power of the executive is mediated by a variety of other institutions such as an


independent parliament, coalition building among parties, federalism, an independent

judiciary. Lijphart summarizes these factors along two dimensions: the party-executive

dimension which concerns mostly the relationship between political parties, the executive,

and parliament, and the federalism-unitarism dimension which is rather independent from the

former and constituted by factors such as a strong or weak judiciary, bicameralism vs. one

parliamentary chamber, federalism vs. a unitary state and others. Lijphart’s classification of

countries diverges somewhat from the one applied here, however, because he decides to drop

the federalism dimension and use only the party-executive dimension to group the countries.

However, here his classification is taken more seriously than by himself. Only those countries

are classified as consensus democracies, which have positive values in both dimensions, and

only those countries as majoritarian, which have negative values in both dimensions. All other

countries are classified as mixed forms here.

Lijphart argues that consensus democracies matter significantly for policy output and

the quality of democracies at large by, among other things, being more inclusive and more

adequately representing minority interests than majoritarian democracies. Does this translate

into a more open immigration policy? The summary in table 5 casts some doubts.

Table 5: Types of Democracy and Immigration Policies

Restrictive

Moderate

Open

Majoritarian

Democracies

Great Britain

Ireland

France

New Zealand

Mixed Types

Denmark

Finland

Norway

Italy

Portugal

Spain

Australia

Canada

Sweden

USA

Consensus

Democracies

Austria

Germany

Switzerland

Belgium

Netherlands

Source: author’s research and Lijphart (1999: 312)

Similar to the socio-economic modernization model, the relationship between type of

democracy and immigration policies is not very clear and, if anything, reverse to the

expectations. Among majoritarian democracies, there is a tendency towards openness whereas

among the consensus democracies restrictive or less open policies dominate. If consensus

democracies better reflect minority interests than the majoritarian type, then in the realm of


immigration policies it seems that it is not migrants’ interests but rather those of their

opponents which are represented at the policy level.

Introducing the Religious Factor: a Catholic Cultural Effect?

So far, the standard explanatory models of comparative policy research have not yielded clear

results, although some patterns could be identified. In the final round of analysis, the religious

dimension will be introduced and it will be discussed whether F. Castles’ model of “family of

nations” is more appropriate than the others in analyzing variations in immigration policy.

Unlike Castles, however, religion will not be reduced to the confessional heritage or role of

Catholic parties. Instead, following earlier analyses the religious factor is decomposed into a

historico-cultural dimension, i.e. the role of confessional patterns, and a socio-cultural

dimension of religiosity, as measured in church-going rates, further an institutional dimension

of patterns of church-state relations, and finally an actor-oriented dimension of religious

parties and movements (see Minkenberg 2002, 2003a, b).

The first step involves the cultural legacy of religion. In order to measure this legacy,

two dimensions are considered: the confessional composition of a country that, if at all, is the

standard variable of religion’s input in comparative public policy research, and the level of

religiosity as a measure of a country’s “embeddedness” in religious practice (see Bruce 2000:

3). In terms of the secularization argument, the first might be seen as an indicator of a

country’s cultural differentiation, or cultural pluralism, whereas the second points to the

country’s path of secularization as disenchantment. Most texts that emphasize the role of

confessions in a nation’s history classify countries as Catholic, Protestant, or confessionally

mixed, and most of them, as well as some of the public policy literature (see above), assert a

long-lasting influence of these cultural patterns on current policy and politics (see Martin,

1978; Bruce, 1996; Inglehart 1997; Inglehart/Baker 2000). Following David Martin and his

distinction between “crucial events” (such as the success or failure of the Reformation and the

outcome of civil wars and revolutions) on the one hand, and “resultant patterns” on the other

(for example, the British, American, Russian, Calvinist, and Lutheran patterns), three

categories will be used for the countries under consideration: (1) cultures with a Protestant

dominance, resulting either from a lack of Catholics (the Scandinavian countries) or because

Catholic minorities arrived after the pattern had been set (England, the United States); (2)

cultures with a Protestant majority and substantial Catholic minorities according to the


historic ratio of 60-40 (the Netherlands, Germany, Switzerland)4 where a cultural rather than a

mere political bipolarity has emerged along with subcultural segregation; (3) cultures with a

Catholic dominance and democratic or democratizing regimes (France, Italy, Belgium,

Austria, Ireland) that are characterized by large political and social fissures, organic

opposition, and secularist dogmas (p. 119).5

The second component of the cultural legacy is the actual degree of attachment to

established religion. This is important because high levels of religiosity assure churches high

legitimacy as political actors. Moreover, religiosity may be a better predictor for public policy

than confessional composition alone if the question whether a country is Catholic or

Protestant is held to be less important than whether Catholics or Protestants actually attend

church or believe the teachings of the church. In this analysis, religiosity is measured by

frequency of churchgoing rather than by religious beliefs because it ties religiosity to existing

institutions instead of more abstract religious concepts and values. Data on churchgoing in the

19 countries analyzed here are taken from the 1980s and 1990s waves of the World Values

Survey (see Inglehart/Baker, 2000; Inglehart/Minkenberg, 2000). The data for the 1980s and

1990s are then averaged and the countries are grouped according to the frequency of church-

going with ranging from low (less than 20% who go at least once a month), to medium (20 –

40%), to high (above 40%) (see Minkenberg 2002: 238).

The relationship between the religious legacies of the 19 countries and their

immigration policies is presented in table 6. Again, the overall picture is far from clear.

Neither confessions nor church-going rates correlate with the degree of openness of the

countries’ immigration policies. If there is a “Catholic effect”, it is that Catholic countries,

especially those with high levels of religiosity, are neither restrictive nor open in their control

of immigration, they are right in the middle. This becomes clearer if France, always a special

case among Catholic countries (see also Lijphart 1999: 282), is removed from the Catholic

group. The suggestion to identify a special Southern or Mediterranean group of countries with

regard to their policies (see Castles 1998: 8f.; Baldwin-Edwards 1992) is not supported by the

distribution in table 6. In part, this misconception results from mixing up immigration and

immigration policies (e.g. Faist 1999: 152). While Mediterranean countries share the common

fate of being latecomers as receiving countries, their approach to controlling immigration is

4 The emphasis is on the “historic weight” of the Protestant majority, not the current proportion such as, for

example, that in the Netherlands of the early 1990s where Catholics (36%) outweigh Protestants (26%) and are

rivaled by an equally large group of those with no church affiliation at all. The same applies to Canada where

today Catholics outnumber Protestants (see above table 1, and Fischer Weltalmanach, 1999, p. 561) 5 Historically, countries with a Catholic dominance and a sizable Protestant minority (a reverse of the 60-40 ratio

in category 2) have not materialized – a very clear illustration of “limited diversity” of religious patterns


shared by other, non-Mediterranean countries as well (Belgium, Ireland). Our analysis

suggests that what this group has in common, is their religiosity, not their geography. This is

also true with regard to the growing proportion of Muslims in these countries. Three of the

four countries, all Catholic, where Islam is the second religion (see table 1), employ a

moderate immigration policy. Again, when France is removed because of its distinct

characteristics as a Catholic country with low church-going rates and a strong

Republican/laizist tradition (see Hollifield 1994), the picture becomes even clearer.

Catholicism, even though its doctrine of society is more “holistic” than Protestantism, does

not lend itself to a closing of the doors, even in the face of a large non-Christian minority.

Table 6: Religious Legacy: Confessions, Religiosity, and Immigration Policies

Restrictive

Moderate

Open

Predominantly

Protestant

Denmark

Finland

Norway

Great Britain

Australia

New Zealand

Sweden

USA

Mixed Protestant

Germany

Switzerland

Netherlands

Canada

Catholic

Austria

Belgium

Ireland

Italy

Portugal

Spain

France

Note: Countries in bold are those with high religiosity; countries in italics with low religiosity.

Some other patterns stand out in table 6, as well. With the exception of Great Britain, the two

Protestant groups divide up into opposite camps of immigration policies. As the Scandinavian

group demonstrates (with the exception of Sweden), secularization does not result in a more

liberal immigration policy, although a declining significance of established churches might

facilitate a country’s departure from its exclusionist traditions and its dealing with increasing

cultural diversity. Generally, church-going rates seem less telling than confessional legacies

when it comes to immigration policies. Finally, when looking for a common religious

denominator for the group with open immigration policies, one must go beyond confessions


and church-going rates. As shown in previous analyses, the regime of church-state relations

can also claim a certain explanatory power for variations in particular public policies.

This institutional dimension of religious legacies is measured by the degree of

deregulation of churches in financial, political and legal respects. This procedure applies a

six-point scale developed by Chaves and Cann (1992) and adds two more criteria related to

public support for religious education (Minkenberg 2003a). Chaves and Cann argue with de

Tocqueville that the theoretical focus of state-church relations needs to be adjusted toward

political aspects: “Like Smith, [de Tocqueville] focused on the separation of church and state,

but he highlighted the political rather than the economic aspect of that separation: the

advantage that religion enjoys when it is not identified with a particular set of political

interests” (Chaves/Cann, 1992: 275; emphasis in original ). Moreover, they suggest that

regardless of the official relationship between church and state, Catholic societies are by

definition much less pluralistic in religious terms than Protestant societies and that different

dynamics are at work. But as the data in table 1 have demonstrated, this historical inequality

is already in the process of revision.

For the purpose of the analysis here, the church-state scale is summarized into a three-

fold typology: countries with full establishment (such as the Scandinavian countries),

countries with partial establishment (such as Germany but also Italy and Great Britain), and

countries with a clear separation of church and state (such as the US and France) (for details,

see Minkenberg 2002, 2003b).

Table 7: Church-State Relations and Immigration

Restrictive

Medium

Open

Separation

Ireland

Australia

New Zealand

USA

Canada

Netherlands

France

Partial establishment

Germany

Switzerland

Austria

Great Britain

Belgium

Italy

Portugal

Spain

Full establishment

Denmark

Finland

Norway

Sweden

Note: Countries in bold are Catholic, countries in italics are predominantly Protestant countries.


Table 7 shows that more so than in the case of Catholicism or secularization (as

disenchantment), institutional differentiation of church and state corresponds rather clearly

with the type of immigration policy. That is, the more separation of state and church, the more

open the immigration policy. The one notable outlier is Sweden where, however, a

disestablishment process has set in in the late 1990s in part as a response to the growing

immigration (see Gustaffson 2003). More specifically, and to take Sweden into account, the

pattern is that Protestantism, in conjunction with a separationist regime, correlates with open

immigration policies.

This finding relates to another factor, which is indirectly related to religion, i.e. the

nation-building and democratization processes of these countries. The pattern indicates a

close link between processes of nation-building and secularization on the one hand, and the

emergence of the current church-state relationship on the other. With the exception of France

and the Netherlands, all countries in the upper right field are former British colonies and

countries of immigration. As such, they are characterized by their separationist model of

church-state relations in distinct opposition to their former “mother country” Great Britain

and its traditional state church. In the Australian case, the initial adoption of the British model

of establishment when increasingly faced with a denominational pluralization resulted in the

replacement of the British model by the American model of separation. This took place

already during colonial times, initiated by the New South Wales Church Act of 1836 and was

completed by and large at the end of the 19th century (see Monsma/Soper 1997: 89-95). Put

differently: in the course of the process of these countries’ separation from Great Britain,

nation-building was intertwined with the process of separating church and state while keeping

the Westminster model of democracy. In contrast to this pattern, the Scandinavian countries

experienced nation-building along with parliamentarization and maintenance of the state

church model (see von Beyme 1999: chap. 2).

Again, this points at the necessity to modify the “family of nations concept” proposed

by F. Castles (1998: 8f.). While there is some support for the existence of a Catholic family

(in a more rigid version than Castles suggests) and – most clearly – for a Scandinavian family,

his English speaking family is divided up into the British Isles (with a moderate immigration

policy) and the former colonies or settler countries (with an open policy). But the latter is

joined by three European countries with very few similarities to the settler countries, except

for the institutionalist regime of church-state relations and the regulation of religious

pluralism (with Sweden lagging behind).


The final step in the analysis of religious factors in variation of immigration policies

concerns the role of religiously oriented parties. In analogy to the studies of strong left-wing

parties and generous welfare states, one might expect a relationship between the presence of

these parties and a restrictive output in immigration policies. In fact, the most direct link

between religion and politics at the intersection of the electoral and policy-making levels

exists where explicitly religious parties, most notably Christian Democratic ones, play a role

in the party system. Moreover, the relevance of religious cleavages in the contemporary

Western world has been demonstrated by a variety of election studies. While the class

cleavage has undergone a steady decline in significance, the religious cleavage in terms of the

relationship between religiosity (as measured by church attendance; see above) and left-right

voting behavior has stayed rather stable. In the US, there was even a slight but steady increase

of religious voting in the United States, which can be attributed to the growing mobilization

efforts of the New Christian Right (see Dalton, 1996: 176-185; see also Minkenberg, 1990;

Inglehart, 1997).

In order to arrive at a measure that captures a religious (Christian) instead of a merely

Catholic partisan impact, the countries are classified according to the role of religion in

particular parties’ identity and programme and their relationship to religious groups, the

salience of the religious cleavage in voting behavior and the length of these parties’

participation in national governments (for details, see Minkenberg 2002). The resulting 6-

points-scale war summarized in three categories, ranging from low to medium to high

religious impact.

Table 8 depicts an interesting role of these parties. What has been shown with regard

to other social policies, i.e. that a strong Christian Democracy corresponds with a moderate

abortion ruling and family policies and reflects a particular policy profile of Christian

Democracy in association with a larger and distinct vision of society (see van Kersbergen,

1995) disappears. Instead, a more general correlation occurs: again with some notable

exception (here: the Netherlands), the higher the religious partisan impact, the more restrictive

the immigration regimes. Interestingly, the group of Christian Democratic parties spreads

across the scale of immigration policies, and again, the Scandinavian group without Sweden

stands out as a distinct type of country also with regard to religious partisan impact. Whereas

in these countries, as in Germany and Austria, the traditional concept of a homogenous nation

seemed to have informed also party politics, especially on the right, this is not the case with

the Netherlands and their Christian Democrats, which unlike their Eastern neighbor faced a


history of post-colonial immigration and subscribed to a view of Dutch culture which was less

determined by notions of ethnicity and closedness (see van Amersfoort/van Niekerk 2003).

Table 8: Immigration Policies, Religious Partisan Impact, and Religiosity

Restrictive

Medium

Open

Low religious partisan

impact

Canada

Australia

New Zealand

France

Medium religious

partisan impact

Switzerland

Ireland

Portugal

Spain

Great Britain

United States

Sweden

High religious partisan

impact

Austria

Germany

Denmark

Finland

Norway

Italy

Belgium

The Netherlands

Note: Countries in bold are those with a high level of religiosity; countries in italics are those with a

low religiosity. Countries that are underlined are those with strong Christian Democratic elements in

the party system.

Conclusions

This paper started with the observation of an ongoing and in some respects increasing

significance of religion in the politics of Western democracies and linked it to processes of

pluralization and globalization, which in turn are related to migration moves across the world.

It raised the issue how the growing complexity and cultural diversity of Western countries in

the face of new immigration waves affects the functioning of democracies and in particular

the politics of immigration control. The paper showed a considerable diversity in immigration

policies in the West, not just between the “settler countries” and the European countries but

also within these categories. It also demonstrated that contrary to some claims in the

literature, standard models of comparative public policy research cannot convincingly account

for this diversity and suggested to add religion as another factor. This factor, however, needs


to be disaggregated and differences in confessional, cultural, institutional and party political

respects have to be taken into account. As a general conclusion, a modified “families of

nations” concept (F. Castles 1998) may be a better frame of analysis than the standard models.

This concept should adjust for the interplay of nation-building, religious traditions, and

institutional management of cultural diversity. It also needs to pay attention to the role of

parties, although the uniformity of Christian Democracy (van Kersbergen 1995) collapses in

the face of immigration related issues. It seems to be superseded by national cultural

traditions.

Finally, the analysis needs to proceed and include, as a complement to immigration

policies, the politics of integration (see Hammar 1985), in particular the integration of non-

Christian religious minorities in countries which have seen themselves as traditionally

homonenous (such as Catholic countries). First sketchy evidence suggests that the political

and cultural integration of non-citizens does not neatly correspond with the openness of

immigration policies. Rather, when taking into account voting rights for non-nationals (see

appendix II), Canada, Australia and the United States are among the least inclusive countries

(while having the most open immigration policy). Only in New Zealand and Sweden does an

open immigration policy match up with an inclusive integration policy. In a similar vein, the

degree of social integration of “guest workers” in Germany clearly exceeds that of labour

migrants in France (Kastoryano 2002). More comparative research also needs to be done

regarding civil liberties of religious minorities, in particular the large and growing group of

Muslims (Hunter 2002). In the 1980s, Tomas Hammar observed that the politics of

multiculturalism seemed to diverge more among the 19 democracies than did the immigration

policies (Hammar 1985: 294). The current debate about headscarves indicates some

convergence in Europe, but the recognition of Islamic education still diverges sharply across

in Western democracies (see Boyle/Sheen 1997; Escudier 2003; Monsma/Soper 1997).

References

Addi, Lahouari et al.2003. Islam et démocratie. Special Issue of Pouvoirs 104. Paris: Seuil. Aleinikoff, T. Alexander, and Klusmeyer, Douglas, eds. 2000. From Migrants to Citizens:

Membership in a Changing World. Washington, DC: Carnegie Endowment for International

Peace.

Aleinikoff, T. Alexander, and Klusmeyer, Douglas, eds. 2001. Citizenship Today: Global Perspectives

and Practices. Washington, DC: Carnegie Endowment for International Peace.

Aleinikoff, T. Alexander, and Klusmeyer, Douglas, eds. 2002. Citizenship Policies for an Age of

Migration. Washington, DC: Carnegie Endowment for International Peace.

Almond, Gabriel A./Powell, G. Bingham, Jr. 1978. Comparative politics. System, process, and policy.

(2nd

rev. ed.). Boston/Toronto: Little, Brown.


Almond, Gabriel A., and Powell, G. Bingham, Jr., eds. 1992. Comparative Politics Today. A

Worldview. New York: Harper Collins.

Anderson, John. 2003. Religious Liberty in Transitional Societies. The Politics of Religion.

Cambridge: Cambridge University Press.

Bader, Veit. 1999. Religious Pluralism. Secularism or Priority for Democracy? In: Political Theory 27

(October), 597-633.

Baldwin-Edwards, Martin. 1992. Immigration after 1992. In: Policy and Politics 19, 3, 199-211.

Baldwin-Edwards, Martin, and Martin Schain, eds. 1994. The Politics of Immigration in Western

Europe. London: Frank Cass.

Barber, Benjamin. 1996. Jihad vs. McWorld. New York: Ballantine.

Bauböck, Rainer, and Dilek Çinar. 1994. Briefing Paper: Naturalisation Policies in Western Europe.

In: Baldwin-Edwards/Schain, eds., 192-196.

Bauböck, Rainer, and Dilek Çinar. 2001. Nationality Law and Naturalization in Austria. In:

Hansen/Weil, eds., 255-272.

Betts, Katharina. 1995. Immigration to Australia: a New Focus for the 1990s? In: F. Heckmann and

W. Bosswick, eds. Migration Policies: a Comparative Perspective. Stuttgart : Ferdinand Enke

Verlag, 59-93.

Blion, Reyald, Catherine Winthol de Wenden, and Nedjma Meknache. 2003. French country report in

immigration management. Bruxelles: Migration Policy Group

(http://migpolgroup.com/publications, March 2004).

Böcker, Anita, and Dietrich Thränhardt. 2003. Einbürgerung und Mehrstaatigkeit in Deutschland und

den Niederlanden. In: Thränhardt/Hunger, eds., 117-134.

Bommes, Michael. 1999. Migration und nationaler Wohlfahrtsstaat. Ein differenztheoretischer

Entwurf. Opladen/Wiesbaden: Westdeutscher Verlag.

Bommes, Michael, and Jost Halfmann, eds. 1998. Migration in nationalen Wohlfahrtsstaaten:

theoretische und vergleichende Untersuchungen. Osnabrück: Universitätsverlag Rasch.

Boyle, Kevin, and Sheen, Juliet, eds. 1997. Freedom of Religion and Belief. A World Report.

London/New York: Routledge.

Brubaker, Rogers. 1992. Citizenship and Nationhood in France and Germany. Cambridge: Cambridge

University Press.

Bruce, Steve, 1986. God Save Ulster! The Religion and Politics of Paisleyism. Oxford: Oxford

University Press.

Bruce, Steve. 1996.Religion in the Modern world. From Cathedrals to Cults. Oxford/New York:

Oxford University Press.

Bruce, Steve, 2000. Fundamentalism. Oxford: Polity Press.

Bruce, Steve. 2002. God is Dead. Secularization in the West. Oxford: Blackwell.

Calic, Marie-Janine. 1998. Religion und Nationalismus im jugoslawischen Krieg. In: Heiner

Bielefeldt/Wilhelm Heitmeyer, eds. Politisierte Religion. Frankfurt/Main: Suhrkamp, 337-359.

Casanova, José. 1994. Public religions in the modern world. Chicago/London: University of Chicago

Press.

Castles, Francis, ed. 1993. Families of nations. Patterns of public policy in Western democracies.

Aldershot: Dartmouth.

Castles, Francis. 1998. Patterns of Public Policy. Patterns of post-war transformation. Cheltenham:

Edward Elgar.

Castles, Stephen. 1998. Einwanderung und Sozialpolitik in Australien. In: Bommes/Halfmann, eds.,

171-197.

Castles, Stephen, and Miller, Mark. 2003. The Age of Migration.3rd

ed. New York: Palgrave.

Chaloff, Jonathan. 2003. Italian country report in immigration management. Bruxelles: Migration

Policy Group (http://migpolgroup.com/publications, March 2004).

Chaves, Mark, and Cann, David E. 1992. Regulation, Pluralism, and Religious Market Structure. In:

Rationality and Society 4, 3, 272-290.

Citizenship and Immigration Canada. 2004a (http://www.cic.gc.ca/english/citizen/howto-e.html, Feb.

29, 2004)

Citizenship and Immigration Canada. 2004b(http://www.cic.gc.ca/english/sponsor/index.html, Feb.

29, 2004)

http://migpolgroup.com/publications


http://www.cic.gc.ca/english/citizen/howto-e.html

http://www.cic.gc.ca/english/sponsor/index.html


Cornelius, Wayne A., Martin, Philip L., and Hollifield, James F., eds. 1994. Controlling Immigration.

A Global Perspective. Stanford: Stanford University Press.

Dalton, Russell J. 1996. Citizen Politics.2nd rev. ed. Chatham House: Chatham House Publishers.

Davie, Grace, 2000. Religion in Modern Europe: A Memory Mutates. Oxford: Oxford University

Press.

Easton, David. 1965. A Systems Analysis of Political Life. New York/London/Sydney: John Wiley &

Sons.

Eckert, Julia. 2003. Die Verstetigung des Konflikts: zur Rolle von Religion im Hindu-Nationalismus.

In: Minkenberg/Willems, U., eds., 346-366.

Efionayi-Mäder, Denise et al. 2003. Swiss country report in immigration management. Bruxelles:

Migration Policy Group (http://migpolgroup.com/publications, March 2004).

Elliott, Jean Leonard. 1993. New Zealand : The Coming of Age of Multiracial Islands. In : Kubat, ed.,

45-59.

Enzinger, Han. 2000. The Dynamics of Integration Policies: A Multidimensional Model. In:

Koopmans, Ruud, and Statham, Paul, eds. Challenging Immigration and Ethnic Relations

Politics. Oxford: Oxford University Press, 97-118.

Ersbøll, Eva. 2001. Nationality Law in Denmark, Finland and Sweden. In: Hansen/Weil, eds., 230-

234.

Escudier, Alexandre, ed. 2003. Der Islam in Europa. Der Umgang mit dem Islam in Frankreich und

Deutschland. Göttingen: Wallstein Verlag.

Esping-Andersen, Gøsta., 1990. The Three Worlds of Welfare Capitalism. Princeton: Princeton

University Press.

Esteves, Alina, Maria Lucinda Fonseca, and Jorge Malheiros. 2003. Portuguese country report in

immigration management. Bruxelles: Migration Policy Group

(http://migpolgroup.com/publications, March 2004).

Fischer Weltalmanach, 1999. Der Fischer Weltalmanach 2000. Frankfurt/Main: Fischer Verlag.

Freeman, Gary P. 1986. Migration and the Political Economy of the Welfare State. In: Annals of the

American Academy of Political and Social Sciences 485, 51-63.

Geddes, Andrew. 1999. The development of EU immigration policy: supranationalisation and the

politics of belonging. In: Geddes, Andrew, and Favell, Adrian, eds. The Politics of Belonging:

Migrants and Minorities in Contemporary Europe. Aldershot et al.: Ashgate, 176-191.

Geuss, Raymond, 2002. Privatheit. Eine Genealogie. Frankfurt/Main.

Gottweis, Herbert, and Prainsack,, Barbara. 2003. Religion, Bio-Medizin und Politik. In:

Minkenberg/Willems, eds., 412-432.

Greven, Michael Th. 1999. Die politische Gesellschaft: Kontingenz und Dezision als Probleme des

Regierens und der Demokratie. Opladen

Gsir, Sonia, Marco Martiniello, Johan Wets. 2003. Belgian country report in immigration

management. Bruxelles: Migration Policy Group (http://migpolgroup.com/publications, March

2004).

Gustafsson, Göran. 2003. Church-State Separation – Swedish Style. In: Madeley/Enyedi, eds., 51-72.

Hammar, Tomas, ed. 1985. European immigration policy. A comparative study. Cambridge :

Cambridge University Press.

Hammar, Tomas. 1990. Democracy and the Nation State. Aliens, Denizens, and Citizens in a World of

International Migration. Aldershot: Avebury.

Hammar, Tomas. 2003. Einwanderung in einen skandinavischen Wohlfahrtsstaat: die schwedische

Erfahrung. In: Thränhardt/Hunger, eds., 227-252.

Hansen, Randall, and Weil, Patrick, eds. 2001. Toward a European Nationality. Citizenship,

Immigration and Nationality Law in the EU. New York: Palgrave.

Haynes, Jeff. 1998. Religion in Global Politics. London/New York: Longman.

Heclo, Hugh. 2001. Religion and Public Policy: An Introduction. In: Journal of Policy History 13 (1),

3-18.

Heinelt, Hubert. 1994. Zuwanderungspolitik in Europa. Nationale Politiken – Gemeinsamkeiten und

Unterschiede. In: Heinelt, Hubert, ed. Zuwanderungspolitik in Europa. Nationale Politiken –

Gemeinsamkeiten und Unterschiede. Opladen: Leske + Budrich, 7-32-





Heitmeyer, Wilhelm, and Dollase, Rainer, eds. 1996. Die bedrängte Toleranz. Ethnisch-kulturelle

Konflikte, religiöse Differenzen, und die Gefahren politisierter Gewalt. Frankfurt/Main:

Suhrkamp.

Hoffmann-Nowotny, Hans-Joachim, and Martin Killias. 1993. Switzerland: Remaining Swiss. In:

Kubat, eds. 231-245.

Hollifield, James F. 1992. Immigrants, Markets, and States. The Political Economy of Postwar

Europe. Cambridge: Harvard University Press.

Hollifield, James F. 1994. Immigration and Republicanism in France. The Hidden Consensus. In:

Cornelius et al., eds., 143-176.

Hollifield, James F. 1997. L’immigration et l’état nation à la recherche d’un modèle national. Paris :

L’Harmattan.

Hollifield, James F. 1998. Migration, Trade and the Nation-State: The Myth of Globalization. In:

UCLA Journal of International Law and Foreign Affairs 3, 2, 595-636.

Hunter, Shireen T., ed. 2002. Islam. Europe’s second religion: the new social, cultural, and political

landscape. Westport.

Huntington, Samuel P., 1996. The Clash of Civilizations and the Remaking of World Order. New

York: Touchstone.

Huntoon, Lisa. 1998. Immigration to Spain. Implications for a Unified European Union Immigration

Policy. In: International Migration Review 32,2 (Summer), 423-450.

Inglehart, Ronald. 1997. Modernization and Postmodernization. Princeton: Princeton University Press.

Inglehart, Ronald, and Baker, Wayne E. 2000. Modernization, cultural change, and the persistence of

traditional values. In: American Sociological Review 65, 19-51.

Inglehart, Ronald, and Minkenberg, Michael. 2000: Die Transformation religiöser Werte in

entwickelten Industriegesellschaften. In: Meyer, Heinz-Dieter/Minkenberg, Michael/Ostner, Ilona,

eds. Religion und Politik - zwischen Universalismus und Partikularismus. Vol. 2 of the Jahrbuch

für Europa- und Nordamerika-Studien. Opladen: Leske+Budrich, 115-130.

Jelen, Ted G., and Wilcox, Clyde. 2002. The Political Roles of Religion. In: idem, eds. Religion and

Politics in Comparative Perspective. The One, the Few, and the Many. Cambridge et al:

Cambridge University Press, 314-324.

Joppke, Christian. 1999. Immigration and the Nation-State. Oxford: Oxford University Press.

Kastoryano, Riva. 2002. Negotiating Identities. Princeton: Princeton University Press.

Kepel, Gilles. 1997. Allah in the West. Islamic Movements in America and Europe. Stanford: Stanford

University Press.

König, Karin, and Bernhard Perchinig. 2003. Austrian country report in immigration management.

Bruxelles: Migration Policy Group (http://migpolgroup.com/publications, March 2004).

Kubat, Daniel, ed. 1993. The Politics of Migration Policies. Settlement and Integration: The First

World into the 1990s. New York: Center for Migration Studies.

Kymlicka, Will, and Norman, Wayne, eds. 2000. Citizenship in Diverse Societies. Oxford

Lijphart, Arend, 1999. Patterns of Democracy. Government Forms and Performance in Thirty-six

Countries. New Haven/London: Yale University Press.

Madeley, John, and Enyedi, Zolt, eds. 2003. Church and State in Contemporary Europe. The Chimera

of Neutrality. Special Issue of West European Politics. London: Frank Cass.

Magnée, Ivo, and Eke Gerritsma. 2003. Dutch country report in immigration management. Bruxelles:


Marty, Martin E., and Appleby, R. Scott, eds.1991. Fundamentalisms Observed. Chicago/London:

University of Chicago Press.

Martin, David. 1978. A general theory of secularisation. London: Blackwell.

Martin, Susan. 2003. Öffnung, Schließung, Ausbeutung. Drei Modelle amerikanischer

Einwanderungspolitik. In: Thränhardt/Hunger, eds., 274-292.

Mendoza, Cristóbal .2003. Labour Immigration in Southern Europe. African Employment in Iberian

Labour Markets. Research in Migration and Ethnic Relations Series. Aldershot: Ashgate.

Minkenberg, Michael. 1990. Neokonservatismus und Neue Rechte in den USA. Baden-Baden: Nomos.

Minkenberg, Michael. 2002. Religion and Public Policy. Institutional, Cultural, and Political Impact

on the Shaping of Abortion Policies in Western Democracies. In: Comparative Political Studies

35, 2 (March), 221-247.




Minkenberg, Michael. 2003a. Staat und Kirche in westlichen Demokratien. In: Minkenberg/Willens,

eds., 115-138.

Minkenberg, Michael. 2003b. The Policy Impact of Church-State Relations: Family Policy and

Abortion in Britain, France and Germany. In: Madeley/Enyedi, eds., 195-217.

Minkenberg, Michael. 2003c. The Politics of Citizenship in the New Republic. In: Kitschelt, Herbert,

and Streeck, Wolfgang, eds. Germany: Beyond the Stable State. Special Issue of West European

Politics. London: Frank Cass, 219-240.

Minkenberg, Michael, and Willems, Ulrich., eds. Politik und Religion. PVS Special Issue 33/2002,

Wiesbaden: Westdeutscher Verlag.

Modood, Tariq, ed. 1997. Church, state, and religious minorities. London.

Morén-Alegret, Ricard. 2002. Integration and Resistance. The relation of social organisations, global

capital, governments and international immigration in Spain and Portugal. Research in

Migration and Ethnic Relations Series. Aldershot: Ashgate.

Moreno Fuentes, Francisco Javier. 2001. Migration and Spanish Nationality Law. In: Hansen/Weil,

eds., 118-142.

Nelson, Barbara. 1998. Public Policy and Administration: An Overview. In: Goodin,

R.E./Klingemann, H.D., eds. A new handbook of political science. Oxford: Oxford University

Press, 551-592.

Nielsen, Jørgen S. 1995. Muslims in Western Europe. Edinburgh.

Nieslen, Jørgen S. 2001. Muslims, the State and the Public Domain in Britain. In: Bonney, Richard et

al., eds. Religion und Politik in Deutschland und Großbritannien. München, 145-154.

Ornbrant, Birgitta, and Markku Peura. 1993. The Nordic Pact. An Experiment in Controlled Stability.

In: Kubat, ed., 202-230.

Price, Charles. 1993. Australia: A New Multicultural Country? In: Kubat, ed., 3-22.

Robbers, Gerhard. 2003. Status und Stellung von Religionsgemeinschaften in der Europäischen

Union. In: Minkenberg/Willems, eds., 88-112.

Robertson, Roland, ed. 1991. Religion and Global Order. New York.

Robertson Roland. 2003. Religion und Politik im globalen Kontext der Gegenwart. In:

Minkenberg/Willems, eds., 581-594.

Rorty, Richard. 1994. Religion as Conversation-Stopper. In: Common Knowledge 3 (1), 1-6.

Rose, Richard. 2002. How Muslims View Democracy: Evidence from Central Asia. In: Journal of

Democracy 13, 4, 102-111.

Salmenhaara, Perttu. 2003. Finnish country report in immigration management. Bruxelles: Migration

Policy Group (http://migpolgroup.com/publications, March 2004).

Schiffauer, Werner. 2003. Medienrevolution und die Zirkulation von Ideen im gegenwärtigen

Weltislam. In: Minkenberg/Willems, eds., 543-558.

Schmidt, Manfred G. 2000. Demokratietheorien. 3. ed., Opladen: Leske + Budrich.

Schmidtke, Oliver.2003. Das kanadische Einwanderungsmodell: Wohlverstandenes Eigeninteresse

und multikulturelles Erbe. In: Thränhardt/Hunger, eds., 205-226.

Sciortino, Giuseppe. 2003. Einwanderung in einen mediterranen Wohlfahrtsstaat: die italienische

Erfahrung. In: Thränhardt/Hunger, eds., 253-273.

Shklar, Judith N. 1989. The Liberalism of Fear. In: Rosenblum, Nancy L., ed., Liberalism and the

Moral Life. Cambridge/London, 21-38, 255-256.

Soysal, Yasemin N. 1994. Limits of Citizenship. Migrants and Postnational Membership in

Europe.Chicago/London: University of Chicago Press.

Stepan, Alfred. 2000. Religion, Democracy, and the ‚Twin Tolerations‘. In: Journal of Democracy, 11

(October), 37-57.

Thränhardt, Dietrich. 2003. Der Nationalstaat als migrationspolitischer Akteur. In: Thränhardt/Hunger,

eds., 8-31

Thränhardt, Dietrich, and Uwe Hunger, eds. 2003. Migration im Spannungsfeld von Globalisierung

und Nationalstaat, Leviathan special issue 22/2003. Wiesbaden: Westdeutscher Verlag.

Van Amersfoort, Hans, and Mies van Niekerk. 2003. Einwanderung als koloniales Erbe: Akzeptanz,

Nichtakzeptanz und Integration in den Niederlanden. In: Thränhardt/Hunger, eds., 135-160.

Van Kersbergen, Kees. 1995. Social Capitalism. A Study of Christian Democracy and the Welfare

State.London/New York: Routledge.



Vertovec, Steven, and Peach, Ceri, eds.1997. Islam in Europe: The Politics of Religions and

Community. Basingstoke: in the United States. 2nd

ed. Washington, DC: CQ Press.

Von Beyme, Klaus 1999. Die parlamentarische Demokratie. Entstehung und Funktionsweise 1789-

1999. Opladen/Wiesbaden: Westdeutscher Verlag.

Walzer, Michael. 1998. Drawing the Line. Religion and Politics. In: Soziale Welt 49, 295-307

Watson, Justin, 1997. The Christian Coalition Macmillan.

Wald, Kenneth. 1992. Religion and Politics. Dreams of Restoration, Demands for Recognition. New

York: St. Martin’s Press.

Weil, Patrick. 1991. La France et ses étrangers. L’aventure d’une politique d’immigration 1938-1991.

Paris: Calman-Lévy.

Weil, Patrick. 2001. Zugang zur Staatsbürgerschaft. Ein Vergleich von 25

Staatsangehörigkeitsgesetzen. In: Conrad, Christoph, and Kocka, Jürgen, eds.,

Staatsbürgerschaft in Europa. Historische Erfahrungen und aktuelle Debatten. Hamburg:

edition Körber Stiftung, 92-111.

Weil, Patrick. 2002. Qu’est-ce qu’un Français ? Histoire de la nationalité française depuis la

Révolution. Paris : Grasset.

Wilensky, Harold. 2002. Rich Democracies. Political Economy, Public Policy and Performance.

Berkeley: University of California Press.

Willems, Ulrich/Minkenberg, Michael. 2003. Politik und Religion im Übergang – Tendenzen und

Forschungsfragen am Beginn des 21. Jahrhunderts. In: Minkenberg/Willems, eds., 13-41.

Wimmer, Andreas. 1998. Binnenintegration und Außenabschließung. Zur Beziehung zwischen

Wohlfahrtsstaat und Migrationssteuerung in der Schweiz des 20. Jahrhunderts. In:

Bommes/Halfmann, eds. 199-221.

Winkelmann, Rainer. 2001. Immigration policies and their impact : the case of New Zealand and

Australia. In: Slobodan Djajić, ed. International migration: trends, policies and economic

impact. London/New York: Routledge, 1-20.

Zapata-Barrero, Ricard. 2003. 2003. Spanish country report in immigration management. Bruxelles:




Appendix I. A Scale of Immigration Policies in 19 democracies (mid-to-late 1990s)

Criteria for Immigration Policy Scale

(lower end: closed, upper end: open)

1. Existence of ius soli

a) non-existent 0 points

b) conditional 1 point

c) unconditional 2 points

2. Naturalization requirements

a) restrictive 0 points

b) medium, or option of purchase 1 point

c) easy/fast 2 points

3. Selection of immigrants:

a) zero-immigration or ethnic quota 0 points

b) post-colonial 1 point

c point system (education, language, age) 2 points

(note : due to EU principle of “free movement”, EU

membership counts +0.5 points)

4. Family reunification (permanent residents)

a) restricted (selected members, waiting period etc.): 0 points

b) conditional (core family) 1 point

c) easy (extended family, short time): 2 points

AUSTRALIA


c) unconditional : 2 points

indirect evidence in Price (1993: 20), Betts (1995: 61)


c) easy/fast: 2 points

after 2 years residence, dual nationality (Betts 1995: 66;; Price 1993: 13), from assimilationism to multiculturalism (Castles 1998: 180- 184)


c) point system (education, language, age) 2 points

policy of 1973 finishes “British preference”, since then point system with emphasis on occupational skills, official “targets”, higher rates of immigration per capita than USA and Canada, end of “assisted passage” by mid-1980s (Betts 1995: 72; Price 1993: 14-15)

4. Family reunification

c) easy 1.5 points

extension of family reunion categories in 1980s, but with some restrictions subject to government decisions; unrestricted entry for core family (“preferential family”), point system for larger family (“concessional family”) (Betts 1995: 73; Price 1993: 13f.)

Total number of points: 7.5 points


AUSTRIA


a) non-existent: 0 points

(Bauböck/Çinar 2001; Weil 2001 : 96)



discretionary, at least 10 years of uninterrupted residence, no dual nationality ((Bauböck/Çinar 2001: 261-264)


a) zero-immigration or ethnic quota: 0.5 points

only guestworker system, reluctance to repatriate displaced Germans ((Bauböck/Çinar 2001: 258) plus 0.5 for EU


a) restricted (selected members, waiting period etc.): 0.5 points

only nuclear family, age limit for children (15 y), quota restrictions (König/Perchinig 2003: 21).

Total number of points 1 point

BELGIUM


b) conditional 0.5 points

severe restrictions on ius soli (parents’ declaration for child, at state’s discretion) (Liénard-Ligny 2001: 203; Weil 2001: 95)



3 years waiting period, dual nationality (Liénard-Ligny 2001: 204-207; Weil 2001: 96)



“guest worker system”, labour market migration (Gsir et al. 2003: 2; personal communication with Marco Martiniello, March 2004), plus 0.5 points for EU



only nuclear family/married persons with some exceptions, based on bilateral agreements with third countries (Gsir et al. 2003: 17f., personal communication with Marco Martiniello, March 2004)

Total number of points: 4 points


CANADA


c) unconditional: 2 points

“Could I be a Canadian citizen and not know it? In general, if you were born in Canada you are a Canadian citizen. You are also a Canadian if you were born in another country after 15 February 1977 and one of your parents was a Canadian citizen before your birth.” (Citizenship and Immigration Canada 2004a)



(Schmidtke 2003: 212, 214; Weil 2001: 96)


c) point system (education, language, age) 1.5 points

(Schmidtke 2003: 210-212)


c) easy 2 points

“Canadian citizens and permanent residents living in Canada, 18 years of age or older, may sponsor close relatives or family members who want to become permanent residents of Canada. Sponsors must promise to support the relative or family member and their accompanying family members for a period of three to 10 years to help them settle in Canada.” (Citizenship and Immigration Canada. 2004b)

Total number of points 7.5 points

DENMARK



(Ersbøll 2001: 236 ; Weil 2001 : 95)


a) restrictive: 0 points

7 years waiting period, no dual nationality (Ersbøll 2001: 240-244; Weil 2001 : 96)



guest worker system (Ersbøll 2001: 246f.) plus 0.5 points for EU membership



nuclear family and unmarried partners but restrictive age and other requirements (Stenum 2003: 12-14)



FINLAND



ius soli only if a child born in Finland does not acquire nationality of another state (Ersbøll 2001: 236; Weil 2001: 95)


a) medium 1 point

(5 year residence requirement, no dual nationality (Ersbøll 2001: 241; Weil 2001 : 96)



“guest worker system” and restrictive policy, based on security concerns (until 1990) (Ersbøll 2001: 247f.; Salmenhaara 2003: 2) plus 0.5 points for EU membership


a) restricted (selected members, waiting period etc.): 0.5 points

only nuclear family, with restrictions for spouses’ activities and high financial requirements (Salmenhaara 2003: 18f.)


FRANCE



(Weil 2002 : 249)


b) medium, or option of purchase: 1.5 points

5 year residence requirement , with waiver for Francophone countries, but administrative hurdles, dual nationality (Bauböck/Çinar 1994: 193; Weil 2001: 96; Weil 2002: 249-251, 256)


b) post-colonial: 1.5 points

Limited recruitment in Francophone countries even after 1974 recruitment stop; openness to and special efforts to recruit foreign students (favors Francophone countries) (Weil 1991: 208; 229-239) plus 0.5 points for EU



only spouse and dependent children, requirements for sponsor: 1 year residence and “regular life” in F, sufficient resources, housing (Weil 1991: 228f.; Blion et al. 2003: 17f.)

Total number of points : 6 points


GERMANY


c) non-existent (prior to 2000) : 0 points


a) restrictive (and loosened): 0.5 points

10 year residence requirement for 2nd

generation, (early 90s), no dual nationality (Bauböck/Çinar 1994: 193); mid-90s: assimilation requirement loosened, as-of-rule for 1

st generation after 15 years, for

2nd

and 3rd

generation after 8 years (Joppke 1999: 202-204)



no legal immigration after 1973 except for family reunification and asylum (Joppke 1999: 85). But open for ethnic Germans until mid-90s; plus 0.5 points for EU membership



“relatively unrestricted entry for the nuclear family of spouses and children, and sharply reduced entry rights for extended family “ (Joppke 1999: 117)


GREAT BRITAN


b) conditional: 1 point

British Nationality Act of 1981: “partial abolishment of ius soli”, “partial introduction of ius sanguinis” (Joppke 1999: 112f., 144)


b) medium, or option of purchase: 1 point

5 year residence requirement, dual nationality (Bauböck/Çinar 1994: 193; Weil 2001: 96)


b) post-colonial (+EU) 1.5 points

Emphasis on Commonwealth, after 1981 ethnic connotations (Joppke 1999: 113), plus 0.5 points for EU membership



“relatively unrestricted entry for the nuclear family of spouses and children, and sharply reduced entry rights for extended family “ (Joppke 1999: 117)



IRELAND



according to 1935 and 1956 Act (Symmons 2001: 279f.)


b) mediuim: 1 point

5 year residence requirement according to 1956 Act, 3 year waiting period for spouses, dual nationality (Symmons 2001: 284f.)



ethnic preference and selected labour market immigration (MacVeigh 2003: 1-4) plus 0.5 points for EU



nuclear family only, no waiting period but no access to labour market for spouse (MacVeigh 2003: 14f.)


ITALY



1992 Nationality Law allows ius soli only for children of unknown parents, at the same time ethnocultural definition of nationhood (extension of nationality to descendents of Italian emigrants) (Sciortino 2003: 272).


a) restrictive: 0.5 points

10 years of uninterrupted residence (1992 law, before: 5 years) (Sciortino 2003: 271; Weil 2001: 96), dual nationality after 1992 (Koslowski 2000: 145)


a) zero-immigration 1 point

restrictions for entry and residence (except for Italian emigrants); zero immigration loosened in 1980s, equal access to social benefits but bureaucratic arbitrariness (Sciortino 2003: 268; 270f.) +0.5 for EU



relatively unrestricted for spouse or dependent children, no siblings, no adult children (Chaloff 2003: 10f.)



NETHERLANDS


b) conditional: 1.5 points

since 1953 ius soli for all immigrant children of 3rd

generation, (Böcker/Thränhardt 2003: 125), mixture of ius soli and ius domicilis



very liberal dual nationality rule, option for Dutch nationality in 2nd

generation (1985 law), very high naturalization levels (Böcker/Thränhardt 2003: 126f.)



preference for labour immigration from former colonies: automatic right to entry and residence, enhanced by liberal naturalization rules (van Amersfoort/van Niekerk 2003: 158-160) +05. for EU


c) easy 2 points

Family reunification from third-country immigrants is easier for EU citizens

than for Dutch citizens (Böcker/Thränhardt 2003: 133f.), unmarried partners

included, no housing conditions but financial requirements

(Magnée/Gerritsma 2003: 32-35)

Total number of points : 7 points

NEW ZEALAND



indirect inference from analogy to Australia in Winkelmann (2001)



Citizenship Act of 1977: a single citizenship granting procedure instead of registration

and naturalization, 3 years of residence (Elliott 1993: 57; Winkelmann 2001: 18, n 6))


b) between point system and post-colonial: 1.5 points

1974 Immigration Policy: end of White New Zealand policy but still automatic right of entry for certain Commonwealth nations, official agreement with the Netherlands (quota), in 1980s opening up to Pacific Island immigration, 1991 abandonment of occupational priorities, point system (Elliott 1993: 50; Winkelmann 2001:6f., 8f.)



unrestricted for spouse and children, parents and siblings (only if single) allowed if

they are sole surviving members of the family to be reunited (Elliott 1993: 49)



NORWAY



(inference from Denmark and literature)



seven year residence requirement, no dual nationality (Ombrant/Peura 1993: 222)


a) zero-immigration or ethnic quota: 0 points

only guest worker system (Ombrant/Peura 1993: 224)



family reunification as main factor of immigration, regulated in Aliens Act (Ombrant/Peura 1993: 224, 226)

Total number of points: 1 point

PORTUGAL



“In 1981, a new nationality law was passed (Lei 37/81, 3 October 1981) which completely abandoned the ius soli principle, with children of non-Portuguese nationals born in Portugal being considered foreigners from 1981.“ (Morén-Alegret: 2002: 97)



“In 1994 an amendment was passed [to the nationality law Lei 37/81], but the only remarkable change was that the new law established tougher criteria for nationals of non-Portuguese speaking countries to naturalise (Lei 25/94, 19 August 1995): until 1994, six years of legal residence were necessary to naturalise as a Portuguese citizen for all foreigners; from 1994 onwards, six years are required for those from Angola, Brazil, Cape Verde, Guinea Bissau, Mozambique and Sao Tomé e Principe, but ten years of residence are needed for nationals from other countries.” (Morén-Alegret: 97) Apart of that, also Portuguese knowledge are required. By marriage: three years of legal union. (Mendoza 2003:: 77) Children of foreign parents who are born in Portugal need either six (PALOP countries) or 10 years of legal residence to naturalise. (Mendoza 2003: 77)



“The community of Countries of Portuguese Language (CPLP) was created in 1996 by seven independent countries that share Portuguese as a common official languages.” (Morén-Alegret: 81) The countries of the “lusofonia”-space deserve “privileged links of friendliness and co-operation” with Portugal, and easier conditions for naturalization and other aspects of the juridic statute of the foreigners



only nuclear family, severe restrictions for activities of family members (Esteves et al. 2003: 17f.)



SPAIN


b) conditional: 1 point

Art. 17 (Civil Code) Spaniards are : a) those born of a Spanish father or mother b) those born in Spain of foreign parents if at least one of them is also

born in Spain c) those born in Spain of foreign parents if neither of them have a

nationality or if the legislation of none of their countries of origin gives the child a nationality

d) those born in Spain whose filiation is undetermined (Moreno Fuentes 2001: 131f.)


a) restrictive: 0.5 points

“Spanish law provides for naturalization of legal immigrants after a term of two years for citizens of former Spanish colonies

6, excepting

the protectorate of Morocco, and after ten years of legal residence of nationals from the rest of the world”. (Huntoon 1998: 429). Also: Only one year for those born in Spanish territory and those married with a Spanish citizen (after one year of marriage). (Civil Code, Art. 22). Spain has signed treaties of double nationality with Bolivia, Chile, Colombia, Costa Rica, Ecuador, Guatemala, Honduras, Nicaragua, Paraguay, Peru, Argentina and Dominican Republic. (Moreno Fuentes 2001: 132)


b) between ethnic quota and post-colonial: 1 point basically “guest worker” system, with preference and less restrictions for nationals from former colonies (Mendoza 2003: 63; Morén-Alegret 2003: 86) plus 0.5 points for EU



nuclear family only, some financial and housing requirements, short waiting

period, access to education system and labour market (Zapata-Barrero 2003:

27)


SWEDEN



mixture of ius soli and ius domicilis (Hammar 2003: 237) 2. Naturalization requirements


5 year residence requirement, dual nationality, high levels of naturalization (Bauböck/Çinar 1994: 193; Hammar 2003: 247)



Increasing restrictions in 1990s (Hammar 2003), plus 0.5 for EU 4. Family reunification


for spouses/unmarried partners and unmarried children (Ornbrant/Peura 1993: 207), growing restrictions in the 1990s (Hammar 2003: 249)


6 Includes the states of Iberoamerica, Andorra, Philippines, Guinea Ecuatorial and Portugal and the Sephardic

Jews.


SWITZERLAND



inference from Efionayi-Mäder et al. (2003: 26): reform project to introduce ius soli for 3

rd generation



12 years residence and cultural assimilation requirements (Hoffman-Nowotny/Killias 1993: 240; Wimmer 1998: 216)



rigid guest worker system with small quota since 1970 (Hoffman-Nowotny/Killias 1993: 238-240)



only nuclear family, after five years also unmarried partners (Efionayi-Mäder et al. 2003: 19).


USA



(Joppke 1999)


b) medium, or option of purchase: 1.5 points

several assimilation requirements, “however minimal and ritual” (Joppke 1999: 275), no financial requirements (Weil 2001: 96)


c) restrictions following family-orientation,

more restrictions in 1996 law: 1 point

(see below 4; Joppke 1999: 60; Martin 2003: 283-287.)


c) easy 2 points

“… the system of family reunification proved too deeply entrenched to allow restrictions in favour of skill-based immigration…the Legal Immigration Act of 1990 … basically reaffirm[ed] the priority of family-based immigration as established in 1965” (Joppke 1999: 39)



Appendix II. A Scale of Political Integration Scale (mid-to-late 1990s)

Criterion: Voting Rights for Noncitizens

Political integration (voting rights for non-citizens)

a) non low

b) restricted (only local, cultural affinity, reciprocity) medium

c) full (all permanent residents and/or all levels) high

Points:

0 no franchise for noncitizens CND

1 no franchise for noncitizens, local exceptions AUS, CH, USA

2 local franchise for EU-citizens in member states A, B, D, F, I

3 local franchise based on cultural similarity or reciprocity

plus EU member status P, SP

4 local franchise for all foreign residents after waiting period but

no EU member status N

5 local franchise for all foreign residents after several years

waiting period plus EU member status NL, DK, FIN

6 local franchise for all foreign residents after brief

waiting period plus EU member status IRE

7 all foreign residents in national referenda, regional and local

elections, postcolonial immigrants in all elections

plus EU member status SW, UK

8 voting rights for all foreign residents in general elections NZ

Note:

“voting rights” refers to the right to vote only, “franchise” includes the right to vote and the right to

run as a candidate

Source:

Aleinikoff/Klusmeyer (2002: 48f.)

Michael Minkenberg Tel. +49 (335) 5534-2257 Europa ... · 4.1, p. 50; Schmidt, 2000, Table 14, pp....

Documents

Transcript of Michael Minkenberg Tel. +49 (335) 5534-2257 Europa ... · 4.1, p. 50; Schmidt, 2000, Table 14, pp....