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Comparing Europe and U.S. Why compare? –You can see assumptions that are often unexamined by using a comparative lens. –Understand how institutions operate.

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Presentation on theme: "Comparing Europe and U.S. Why compare? –You can see assumptions that are often unexamined by using a comparative lens. –Understand how institutions operate."— Presentation transcript:

1 Comparing Europe and U.S. Why compare? –You can see assumptions that are often unexamined by using a comparative lens. –Understand how institutions operate to affect immigrants –Understand the experience of Muslims in the US and Europe

2 Comparative View Birthright Citizenship vs. The Alternative –The experiences of countries such as Germany, France, Switzerland and Belgium show that restrictive citizenship regimes do not lead to emigration, but rather to deep social problems, lack of integration and decreased social mobility.

3 Comparative View Industrialized Countries are all facing Low Birth Rates and the Need for Immigrants The third demographic transition: Transition to diversity

4 Comparative View Demography and Destiny : The Better Position of the United States with Respect to Population Aging –Europe’s median age is climbing 2000 37.7 204047.9 Italy 52.7 –Europe’s median TFR 1.31 (TFR=2.1 for replacement) –US TFR 2.01 Non Hispanic Whites 1.87 Hispanics 2.75 Blacks 2.10



7 Total Fertility Rates – Europe and North America 1950-2000 ____________________ Source:United Nations In chart minimum value in y axis is 0.5 and crosses at 0.75 In PowerPoint a white fill box has been used to blank out the 0.5


9 Source: Kohler, Billargi and Ortega. Calculated from United Nations medium projections.



12 Current European Immigrants Southern and Eastern Europeans moving to Northern and Western Europe. Guest workers who became permanent. Turks to Germany, France and Netherlands. Immigrants from Former Colonies: Indians, Pakistanis, West Indians to Britain, Algerians and Moroccans to France, Surinamese to Netherlands.

13 Current European Immigrants Countries of emigration have become countries of immigration –Italy, Spain, Portugal, Turkey, Ireland Fall of Soviet Union opened up immigration from Eastern Europe to Western Europe Strong human rights orientation, asylum and refugees a large part of immigration flows.

14 Current European Immigrants Former Communist Countries such as Poland, Romania Asylum Seekers, especially from Africa


16 Citizenship By Ascription –place of birth (jus soli) law of the earth –line of descent (jus sanguinis) law of the blood By Naturalization –As a right –At the discretion of the state

17 Citizenship in the U.S. By birth (even if parents are illegal, or here for a short period of time) (jus soli) By birth abroad if parents are citizens (jus sanguinis) By adoption By naturalization if they comply with conditions specified by law

18 U.S. Naturalization Rules 5 year residence Oral and written English ability Knowledge of US history and government Good moral character Oath of allegiance No dual citizenship (ambiguous) –Give up foreign allegiance

19 History of Citizenship Bill of Rights confers rights on “people” not citizens. 1790’s: citizenship goes to “free white persons” Early 19 th Century court cases define Indian tribes as “nations”, designated them as noncitizens. (Not reversed until 1922)

20 14 th Amendment 1868 “all persons born or naturalized in the US are citizens of the US and the state in which they reside” 1870 Congress debated a law that would allow any “person” to naturalize. But they passed a law making anyone of African descent or nativity eligible for naturalization.

21 Naturalization and Race 1882 Chinese Exclusion Act bars “aliens ineligible for citizenship” 1897 case of Mexicans—neither white nor black but the court decided that they could be naturalized because the laws and treaties of the US after the Treaty of Guadalupe Hidalgo promised citizenship to Mexicans living in land the US took.

22 Many court cases 1922 Supreme Court ruled that Japanese were ineligible for citizenship. 1911 Thai, Indian and Koreans were found ineligible. 1912 court turned down a “half breed German and Japanese” and a “quarter breed Spaniard and Filipino”

23 Citizenship denied by race 1910 Census—Syrians, Armenians, Palestinians, Turks and Persians were Asiatics. Eventually won a court order that they were white and could become citizens.

24 Citizenship denied by gender After 1855 an alien wife carried the citizenship of her husband. 1907 Congressional act was passed that if an American woman married an alien she assumed the nationality of her husband. She lost her citizenship and could not naturalize until her husband did.

25 Citizenship and Gender 1922 Cable Act. Women were allowed to have independent citizenship. They no longer got automatic citizenship through marriage. But until 1931 if a woman married an alien ineligible for citizenship (an Asian) she became ineligible for citizenship too.

26 Liberalization of Citizenship 1943 ban on citizenship was lifted for Chinese 1946 Filipinos and East Indians 1952 McCarren Walter Act –The right of a person to become a naturalized citizen of the US shall not be denied or abridged because of race or sex or because such person is married”

27 Data on Naturalization CIS does not track people once they enter. People are lost when they return home, or die. Census includes illegals and they are not eligible to naturalize. Surveys are the best source, but size is usually inadequate.

28 US does little to promote naturalization No notice is sent to immigrants or refugees to let them know when they are eligible. Very little public funding pays for language or civics classes. Long backlogs of people waiting for citizenship to come through.

29 Why do countries differ in how immigrants fare? Grand Narratives Demographics of who immigrates? Institutional Differences –Welfare state and social supports –Educational systems –Structure of labor market

30 Axes of Difference in European Policy Towards Immigrants Citizenship –Criteria for formal access –Ease of access –Blood vs Territory Cultural Obligations –Pluralism vs. Assimilation –Multiculturalism

31 Grand Narratives France: Republican Model Canada: Multiculturalism Germany: Ethnic model Nationhood US, Canada and Australia: Settler Societies

32 Countries of Immigration? Germany: Until 1990’s: “We are not a country of immigration”. (Post war immigrants and their children are 10% of population). Journal of Ethnic and Migration Studies –Advice to authors: “Avoid “immigrant” for non migrant members of the second generation”

33 Laws on Citizenship Vary France and Britain have jus soli conditionally. (France: Ask at age 16-21). Extensive naturalization for ex colonials. Yet there remains much ambivalence about French citizenship for Algerians. Sweden and Netherlands have highest rates of naturalization. Allow voting in local elections before naturalization. Germany, Austria, Switzerland most restrictive.

34 1990’s convergence Countries with restrictive/lineage based rules have widened access to citizenship: Belgium, Germany, Switzerland, Netherlands. France—tighten laws. Assimilation, “becoming French” very important. “Head scarf” issue.

35 Birthright Citizenship Australia, Ireland, India, New Zealand, the United Kingdom, Malta, and the Dominican Republic — have modified birthright citizenship in recent years.

36 German Restrictions Citizenship has been based on descent. Ethnic Germans from Poland and Soviet Union are eligible to claim German citizenship.

37 German Case Before 1993: second generation treated the same as the first. Requirements included long period of residence, competence in German language, large fee, clean police record, surrender of previous citizenship. After 1993, the second generation did not have all these requirements but did have to surrender previous citizenship and apply for citizenship. Clashes with Turkish inheritance laws.

38 German Citizenship 2000 first new citizen law in 90 years. Children born to foreigners automatically receive citizenship, provided one parent has been a legal resident for 8 years. Children can also hold nationality of parents, but must choose one country or the other by age 23.

39 Switzerland 20% of the population is “foreign” Immigrants must wait 12 years before applying. Local governments inspect home Local cantons vote on candidates. Even the third generation has no automatic citizenship


41 Boundaries Richard Alba Enacted social distinctions, i.e., distinctions that individuals make in their everyday lives and that shape their actions and mental orientations towards others; typically embedded in a variety of social and cultural differences; matter when linked to unequal life chances and status

42 Key points Boundaries are not the same everywhere Boundaries can change over time –native groups may seek to make boundaries less porous –boundaries may be weakened by structural changes, e.g., occupational shifts associated with demographic change

43 Boundaries: bright vs. blurred Bright boundary is unambiguous, blurred one may be ambiguous (for some individuals or in some contexts) Race vs. language (bilingualism)

44 Change Over Time Boundary crossing –Individual level assimilation Boundary blurring –Individuals location can be indeterminate Boundary shifting –Former outsiders become insiders

45 Boundaries: bright vs. blurred Bright boundary: –assimilation less likely –assimilation requires boundary crossing, i.e., is individualistic, less gradual, typically risky, does not allow “hyphenation”

46 Boundaries and the Second Generation France and Germany : religion is a bright boundary Germany: citizenship is a bright boundary Individual boundary crossing? US: Mexicans and race, blurred vs bright boundary?

47 Race, Color and Culture In Europe: Much less comfortable with the concept of race. –France: ethnicity not a statistical category –Britain: ‘Race’ in quotation marks –Germany: Blood, race, Nazi connotations In Europe: Immigrants tend to be stigmatized based on culture rather than color.

48 The Second Generation In U.S. the segmented assimilation model asks what happens when the second generation is defined racially and adopts an oppositional stance that comes from African American underclass? What happens without a minority racial underclass? Is oppositional culture generic to negatively priveleged groups? Or is it specific to race? North Africans in France and Turks in Germany are racially/religiously “othered”. Upward mobility blocked.

49 Islam in Europe Boundaries separating immigrants and natives. Long standing establishment of Christianity in Western Europe—support for religious schools, religious holidays, funding for churches as national symbols.

50 The Case of Muslims After September 11 th, worries about radical Islam. Is Islam somehow more “culturally different” than other religions? In Europe the dominant discourse is that Islam is seen as a barrier or a challenge to integration and a source of conflict with mainstream institutions.

51 Muslims in US Will Religion become a fault line? Best estimate 2.35 million Muslims in US (65% foreign born, another 7% second generation) Most Arabs in US are Christians In the US most Muslims are educated and well off, while in Europe they tend to be disadvantaged. Evidence that since 9/11, people have begun to self identify as Muslim American. Still, most Muslims in the US do not see any conflict between being Muslim and American. (This is very different in Europe)


53 1. Demographic Data 53 Breakdown of American Muslim population by race / regional origins 2001 Zogby International Survey Ethnic Composition of Muslims in US

54 Religion as Bridge in US Americans are very religious. Europeans are much more secular.


56 French Assimilation Until the 1980’s French official policy was assimilation. 1980s on more of an integrationist policy— money to groups to preserve some aspects of culture. Recently return to assimilation

57 French Assimilation Since 2003, immigrants asked to sign an immigration contract upon arrival. They promise to undergo language training and instruction on values of French society. Get certificate upon completion of training which is necessary for 10 year residence permit. If not, get one year residence permit.

58 French Assimilation View retention of ethnic identity as an obstacle to integration and national solidarity. July 2003 appointed Commission to Investigate Secularism and the French Republic. 25 recommendations, but most attention to headscarf issue

59 Feb 10, 2004 Law Banned conspicuous religious symbols in public schools. Passed by vote 494 to 36 in National Assembly. Broad popular support. Is it anti-Islam or Pro Secularism?

60 2010 French Law Bans all women from wearing face covering in public. “No one can, in the public space, wear clothing intended to hide the face” Public space is defined as “Streets, markets, private businesses, public transport, govt buildings.” National Assembly Vote 335 to 1


62 French Foreign Born Population Algerians 13.4% Moroccans 12.1% Sub Saharan Africans 9.3% Turks 4.1% Southeast Asians also a growing group

63 North Africans in France Early school departure High problems with police High unemployment Residential segregation Segmented assimilation?

64 The Second Generation Very little anti-discrimination laws No affirmative action ZEP zones—zones of priority in education, areas showing high unemployment and high numbers of foreigners.

65 No Ethnic Statistics in France Discrimination hard to document. Are there ghettoes? Systematic police harassment? Higher health problems? Educational disparities. No hyphenated identities Controversies over the place of Islam given the principle of laicite (French secularism) Riots in Fall 2005



68 Schools and Integration Language at home vs. school Parents lack knowledge about school system Parents unable to help with homework, low levels of education, sometimes illiterate

69 Institutional Differences in Schools Across Countries Age at Starting School Degree of Internal Stratification and the Age at which it is Imposed School Financing, Residential Segregation, Religion in Schools Second Chances in Higher Education

70 Germany and Austria Late start to school Earlier selection into rigid tracks Germany—4th grade –Gymnasium– University –Realschule—White collar –Hauptschule—Blue Collar Apprentice system

71 France Early start to school Later age of selection Exams, not teachers National financing Extra funding for immigrant schools

72 Britain Move towards later tracking More second chances at the University Level National financing, but residential segregation is high

73 US Less rigid tracking Much more segregation, interacts with school financing at local level More second chances at the secondary and university levels

74 Outcomes Greater numbers of university graduates of immigrant origin in US, Britain, Netherlands and France More dropouts and unemployment compared to Germany, Switzerland and Austria

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