views updated May 21 2018


CITIZENSHIP. In the modern world, citizenship is a legal status that bestows uniform rights and duties upon all members of a state. Modern citizenship is associated with equality before the law, freedom from arbitrary rule, and a basic sense of human dignity bound up with the idea of human rights. It is a powerful term that evokes not only the rights that citizens may claim, but also the duties to which they are called, including dying for one's country. In early modern Europe, the status of citizen was far feebler and more varied in nature. At the dawn of this period, there were no centralized national states, and the vast majority of the population were servile peasants who lived under the rule of a local lord. The idea of citizenship, that is, a body of free people bound by a common law, was restricted to those who enjoyed full rights of membership in privileged towns, the burghers or bourgeois. There was no concept of universal rights of citizens. Rights took the form of privileges that were legitimated by tradition and distributed inequitably according to place, rank, and membership in other corporate bodiesguilds, parliaments, universities, and the like. Urban citizenship was thus just one form of juridical status that coexisted alongside a wide array of corporate groups entitling members to rights and privileges.


In general, the citizenship of towns offered several kinds of benefits. Only citizens could hold municipal office and perhaps engage in lucrative urban trades. They enjoyed the privilege of being tried in a local court by their peers and were usually entitled to reduced taxes. Citizenship was commonly restricted to the propertied elite. Jean-Jacques Rousseau's Geneva, for example, was divided into an inner core of "citizens" and "bourgeois" who exercised full urban rights, and a wider tier of "inhabitants" and "natives," who had the right to live in the city but not to participate in the most profitable professions or hold municipal office.

The actual type and worth of rights conferred by urban citizenship varied by town. In Zurich and London citizenship was not prerequisite for access to the guilds. In fact, guild membership could be a way to acquire citizenship. In sixteenth-century Antwerp, it was not uncommon for members of the city council to register for citizenship just before taking office. In some cases, acquisition of citizenship was turned into a routine commercial transaction. In theory, the laws of sixteenth-century Bologna made it difficult for naturalized citizens to hold municipal office. In reality, citizens selected for office frequently designated a substitute to fill the post, a practice that amounted to a form of office selling. Nonetheless, urban citizenship might offer important advantages to its members. Citizens of Antwerp (poorters), for example, could not be arrested without cause and were exempt from torture. This was of little concern until the 1540s when the number of registrations for citizenship in Antwerp suddenly jumped. At that time, the town council began to use Antwerp's citizenship rights to protect persecuted Protestants.

Citizenship entailed responsibilities as well as rights. Citizens might be required to serve in the urban militia and to pay local taxes supporting the cost of communal self-government and fortifications. The status of citizen was usually inherited, but it could also be acquired by foreigners. Usually, naturalization required establishing a residence within the city for an extended period of time, paying specified taxes, and taking on other obligations of urban membership. Frequently, citizenship was associated with social and moral qualities. Many central European cities refused citizenship to adulterers and bastards.

Citizenship first became the object of more systematic theoretical reflection in self-governing Italian city-states during the early Renaissance. The recovery of Aristotle and other classical authors, combined with the struggle of Italian city-states to assert their independence from emperors and foreign invaders, stimulated thinkers to clarify the basis of political community. One important strand drew on the work of Bartolus of Sassoferato and his pupil, Baldus de Ubaldis, the most influential jurists working in the Roman law tradition. They provided the first philosophical foundation for viewing the city-state as a fully independent, self-governing corporation of citizens.

A second important tradition drew on Florentine civic humanism. Humanists argued that the best form of government was elective, not monarchical, since elected rulers would best work to achieve the goals of the republic: to attain glory, sustain liberty, and preserve the common good. The civic humanist tradition culminated in the Discourses of Niccolò Machiavelli, who wrote in a period of tumult following the French invasion of Italy in 1494. Looking back to the tradition of the Roman Republic, Machiavelli urged his fellow citizens to prevent decline by practicing virtù. For Machiavelli, virtù meant the patriotic love of the republic that led citizens to place the welfare of the political community above individual interests. Good laws and institutions were also necessary to sustain virtù. Among the latter, the most important were civil religion to foster a spirit of unity and a citizen militia to encourage a spirit of self-sacrifice and bravery.


Given its classical, urban, and corporate roots, citizenship was not easily transferred to monarchical realms, where the king reputedly embodied the state and where vast aristocratic patron-client systems created webs of political obligation. A rudimentary idea of citizenship did distinguish native-born subjects of kingdoms (known as denizens in England, regnicoles in France, and naturales in Spain) from foreigners, who suffered various kinds of disabilities. In Spain, only naturales of the five kingdoms of Aragón could hold offices in their respective kingdoms, engage in transatlantic commerce, or emigrate to the New World. In England, aliens could not vote in parliamentary elections, hold real property, own a British ship, or engage in the profitable colonial trade. In France, foreigners or aubains (a term originally applied to outsiders moving into the jurisdiction of a feudal lord) paid special taxes, and the king could seize their property upon death. Naturalization removed these disabilities. Naturalization might require proof of assimilation into the national culture, as was the case in Spain, or merely be a routine bureaucratic procedure. In France, one had to do little more than offer evidence of Catholicity and French residence and pay the necessary fees. In England, aliens could apply to Parliament for a private naturalization act, a route that was generally closed to Jews, Catholics, and Dissenters. A lesser status of "free denizen," which bestowed the right to participate in the colonial trade, could be purchased by those groups, but it did not grant exemption from steep alien custom duties.

In most cases, the status of a woman, whether at the municipal or national level, followed that of her husband. At times, however, foreign women married to foreign men seeking naturalization were required to be naturalized independently of their husbands. Because women generally could not hold office or practice lucrative trades, naturalization was of less worth to them than to men. Citizenship for women tended to remain a passive status that granted basic judicial protections, but did not authorize vital rights of political participation. Later, during the French Revolution, the secondary status of women was reconfirmed by the overt creation of "active" and "passive" categories of citizenship.

Throughout the early modern period, the quest for religious freedom and the evolution of citizenship remained closely tied. In the medieval world, the political community was also a closed community of Christian believers. Jews were outsiders, frequently banished, and allowed residence in certain countries only if they lived in specified locales, wore distinctive dress, paid special taxes, and the like. With the Reformation, Christian unity was shattered and states were "confessionalized," so that the enjoyment of civil and political rights became tied to membership in the established church of the realm. Religious dissenters might be prohibited from holding office, bequeathing property, joining guilds, obtaining an education, marrying, bringing up their own children, and receiving a Christian burial. In certain cases, toleration was granted as a concession from the ruler or in limited form, such as the right to private worship. Freedom of religion as a universal right of citizenship, however, was only conceptualized after natural law theory offered a nondoctrinal way of legitimating membership in the state.


The period of religious revolt in the later sixteenth and seventeenth centuries was critical to the rise of absolutist citizenship. Rebellious subjects invoked rights of the "ancient constitution" against absolute monarchs, or cited resistance theories that vested sovereignty in the ambiguous notion of "the people." The bloodshed of the period led royal theorists to define the citizen as a subject who owed unquestioned obedience to the sovereign in return for protection. In his Six Books of the Commonwealth, Jean Bodin stated that the citizen was "a free subject who is dependent on the sovereignty of another" (p. 19). Approximately a century later, in De Cive, or, The Citizen (1642), Thomas Hobbes presented a contractual theory of political society in which men voluntarily gave up the natural rights that they enjoyed in the bellicose state of nature to a ruler or ruling body in order to gain security: ". . . each citizen is called the subject of him who hath the chief command" (p. 68).

Despite Hobbes's theorizing, subjects showed themselves determined to hold onto historic rights. After James II was ousted from the English throne during the Glorious Revolution of 1688, a Bill of Rights declared that hierarchically ordered "estates" would be maintained in their "ancient rights and liberties." At the same time, John Locke's Second Treatise on Government pointed the way toward a far more radical interpretation of rights as abstract, natural, and universal in scope. For Locke, rights were "inalienable," derived from a free and egalitarian state of nature. Governments were not products of dynastic inheritance or divine will: they were artificial creations grounded in popular consent whose central purpose was to secure citizens' rights. Popularized through tracts such as Cato's Letters, a Lockean conception of rights ultimately became one of the major foundations of the American Declaration of Independence.

By the eighteenth century, then, the usage of the word "citizen" had begun to shed its absolutist association with "subject" and break free from the idea of graded ranks and historically conditioned privileges. This transformation was part of a wider linguistic shift. Words connoting a vertical ordering of society organized by notions of deference and command were abandoned or took on new meaning. The word "king" became uncoupled from "nation," which he had previously embodied. The word "society" no longer meant a business partnership, but a universal field of human relations. Social gradations still existed, but they were often described as classes, which implied productivity and individual effort, rather than as estates, orders, or corps, which suggested a preexisting, divinely sanctioned hierarchy. In the article "Citizen" in his Encyclopedia, Denis Diderot defined the citizen not in terms of participation in the privileges of a city, but as "a member of a free society . . . who partakes of the rights of that society and enjoys its privileges."

Two moral qualities were particularly associated with the citizen: utility and virtue. Political economists spread the idea that the most powerful state was the one that counted the greatest number of "industrious" men. The pursuit of plenty, according to these thinkers, was not something to be scorned for its corruption of civic spirit, but to be praised for its ability to unleash national productive power. Utility did not necessarily negate hierarchy, but it did shift the justification for social ranks from innate qualities, like noble birth, to functional attributes available to any hardworking person.

Virtue continued to be defined by reference to classical republican qualities. In his Spirit of the Laws, Montesquieu spoke of virtue in terms of "the love of our country, of the thirst of true glory, of self-denial, of the sacrifice of our dearest interests, and of all those heroic virtues which we admire in the ancients" (Vol. I, Bk. III.5, p. 23). Yet virtue also acquired enlightened overtones of sociability and humanitarianism. Rousseau spoke of virtue not only in terms of patriotic self-sacrifice, but also of sensibility and pity revealed through the inner voice of the conscience. For Rousseau and others, virtue was a humanitarian sentiment most easily found among the common people. By imparting moral worth to ordinary people, virtue legitimated their quest to gain a political voice.

Many rejected the ideals of classical republicanism as a model for citizenship altogether. The direct democracy suitable to small, face-to-face societies like the ancient republics would not work in large, culturally diffuse states. Furthermore, too much popular participation had opened up ancient republics to constant factionalism. Rather than relying on direct democracy, men like Jean Louis de Lolme argued, it would be better to set up a passive system of representation and create institutional checks and balances to channel the interests of the people toward the common good. Ancient republics, furthermore, had practiced slavery, denigrated women and domestic life, spurned commercial development, and even permitted infanticide. Republican citizenship would have to be made compatible with the technological progress, commercial prosperity, and humane virtues that most enlightened elites endorsed.


By the end of the eighteenth century, then, two visions of republican citizenship had emerged. One, often labeled "liberal," was derived from a natural law tradition and emphasized the rights of individuals, representation, and material progress. It was concerned with checking arbitrary power and securing the conditions that would allow men and women to enjoy the fruits of their labor in peace. A second, more activist and communal strand inspired by classical republicanism appealed to civic virtues of self-sacrifice, public-spiritedness, and the constant vigilance of citizens against enemies of freedom.

Jean-Jacques Rousseau brought elements of both traditions together in The Social Contract, a treatise meant to serve as an ideal, not an actual blueprint, for society. According to Rousseau, men in their natural state were free and equal, but they were also amoral and governed by instinct. Men reached their full human potential only through the exercise of citizenship. In the social contract, each individual gave up his powers from the state of nature to everyone else in order to form a state. The essence of citizenship, then, was participation in the social contract, which created a state of morality, civil freedom, equality, and democratic participation. Citizens were bound by law, but remained free, because they imposed laws on themselves. Citizens were equal before the law, because everyone came into the social contract under the same terms. The public interest or "general will" served as the ultimate source of law, because all individuals had sacrificed their private interests to become part of the state. For Rousseau, citizenship was a legal status, but not a passive one, as it implied moral duties and active participation.

The actual transition to a new form of citizenship stemmed from the practical need to make states more competitive in war. In France the monarchy contributed to a more egalitarian definition of society by attempting to tax privileged members of society. Royal reforming ministers and their allies argued that payment of taxes defined citizenship, because all members of society, even the privileged, owed the state taxes in return for protection. As the Physiocrat writer LeTrosne declared in his work on tax reform, ecclesiastical tax exemptions put the clergy "outside the class of citizens" and stripped them "of all right to civil protection" (p. 501). In reply, the most powerful corporate bodies in France, the sovereign courts known as parlements, stretched corporate politics to the breaking point and went beyond their traditional defense of "fundamental laws." Claiming to speak for "the Nation," the parlements stated that the nation had a right to consent to taxes and thereby made themselves virtual co-sovereigns with the king.

The bankruptcy of the French government in 1788 proved that a new organization of the state was necessary. Drawing on political economy and social contract theory, the Abbé Sieyès in What Is the Third Estate? laid out the terms of modern citizenship as a national, egalitarian, and utilitarian status. Citizens were members of the nation, that is, "a body of associates living under common laws" (p. 55). Since privileges were exemptions from the common law, all those who enjoyed privileges, notably the nobility, were noncitizens. Eventually, this logic was used to justify the execution of the king, since an absolute monarch stood outside the common law formed by the social contract and thus could be judged, as Saint Just argued in 1792, "not as a citizen, but as a rebel" (p. 123). Enshrined in "The Declaration of the Rights of Man and of the Citizen" of 1789, citizenship became synonymous with both the enjoyment of fundamental rights and a new vision of national sovereignty. Rather than being one legal status among many in a corporate society, citizenship had become the primary status mediating all other juridical relationships in the state and the primary marker of human worth.

See also Bodin, Jean ; Cities and Urban Life ; Class, Status, and Order ; Democracy ; Diderot, Denis ; Enlightened Despotism ; Hobbes, Thomas ; Locke, John ; Machiavelli, Niccolò ; Monarchy ; Montesquieu, Charles-Louis de Secondat de ; Parlements ; Political Philosophy ; Political Secularization ; Revolutions, Age of ; Rousseau, Jean-Jacques .


Primary Sources

Bodin, Jean. Six Books of the Commonwealth. Edited and translated by M. J. Tooley. Oxford, 1955 (First published in 1573).

Hobbes, Thomas. De Cive, or, The Citizen. Edited by Sterling P. Lamprecht. Westport, Conn., 1982.

Diderot, Denis. Political Writings. Edited and translated by John Hope Mason and Robert Wokler. Cambridge, U.K., 1992. Includes translation of Diderot's article on "Citizen" from his Encyclopedia.

Le Trosne, Guillaume François. De l'administration provinciale et de la réforme de l'impôt. Basel, 1779.

Locke, John. Two Treatises of Government. Edited by Peter Laslett. Cambridge, U.K., 1988.

Machiavelli, Niccolò. The Discourses. Translated by Leslie J. Walker, S. J. Edited by Bernard Crick. Harmondsworth, U.K., 1970. Translation of I discorsi.

Montesquieu, Charles-Louis de Secondat de. The Spirit of the Laws. 2 vols. in one. Translated by Thomas Nugent. New York, 1959. Translation of L'esprit des lois (1748).

Rousseau, Jean-Jacques. The Social Contract. Translated by Maurice Cranston. London, 1968. Translation of Du contrat social (1762).

Saint-Just, Louis Antoine Léon de. "Speech at the Trial of the King, November 13, 1792." In Regicide and Revolution: Speeches at the Trial of Louis XVI. Translated by Marian Rothstein. Edited by Michael Walzer. Pp. 120127. New York, 1974.

Sieyès, Emmanuel Joseph. What is the Third Estate? Translated by M. Blondel. New York, 1963. Translation of Qu'est que le tiers état? (1789).

Secondary Sources

Baker, Keith Michael. "Transformations of Classical Republicanism in Eighteenth-Century France." Journal of Modern History 73 (March 2001): 3253.

Boone, Marc, Simona Cerutti, Robert Descimon, and Maarten Prak. "Introduction: Citizenship Between Individual and Community, 14th18th Centuries." In Statuts individuels, statuts corporatifs et statuts judiciares dans les villes européenes (moyen âges et tempsmodernes), edited by Marc Boone and Maarten Prak. Leuven, 1996.

Brubaker, Roger. Citizenship and Nationhood in France and Germany. Cambridge, Mass., 1992.

Canning, Joseph. "A Fourteenth-Century Contribution to the Theory of Citizenship: Political Man and the Problem of Created Citizenship in the Thought of Baldus de Ubaldis." In Authority and Power: Studies in Medieval Law and Government Presented to Walter Ulmann on His Seventieth Birthday, edited by Brian Tierney and Peter Linehan. Cambridge, U.K., 1980.

Howell, Martha. "Citizenship and Gender: Women's Political Status in Northern Medieval Cities." In Women and Power in the Middle Ages, edited by Mary Erler and Maryanne Kowaleski, pp. 3760. Athens, Ga., 1988.

Kirshner, Jules, and Laurent Mayali, eds. Privileges and Rights of Citizenship. Berkeley, 2002.

Marshall, T. H. Class, Citizenship and Social Development: Essays by T. H. Marshall. Westport, Conn., 1973.

Oldfield, Adrien. Citizenship and Community: Civic Republicanism and the Modern World. London, 1990.

Pocock, J. G. A. "The Ideal of Citizenship since Classical Times." In The Citizenship Debates, edited by Gershon Shafir, pp. 3142. Minneapolis, 1998.

Prak, Martin. "Citizen Radicalism and Democracy in the Dutch Republic: The Patriot Movement of the 1780s." Theory and Society 20 (1991): 73102.

Rahe, Paul. "Antiquity Surpassed: The Repudiation of Classical Republicanism." In Republicanism, Liberty, and Commercial Society, 16491776, edited by David Wootton. Stanford, 1994.

Reinhard, Wolfgang. "Reformation, Counter-Reformation and the Early Modern State: A Reassessment." Catholic Historical Review 85 (July 1989): 383404.

Riesenberg, Peter. Citizenship in the Western Tradition: Plato to Rousseau. Chapel Hill, N.C., 1992.

Sahlins, Peter. Unnaturally French: Foreign Citizens in the Old Regime and After. Ithaca, N.Y., 2003.

Schilling, Heinz, "Civic Republicanism in Late Medieval and Early Modern German Cities." In Religion, Political Culture and the Emergence of Early Modern Society: Essays in German and Dutch History, pp. 360. Leiden, 1992.

Sewell, William H. "Le Citoyen/la citoyenne: Activity, Passivity, and the Revolutionary Concept of Citizenship." In The French Revolution and the Creation of Modern Political Culture, Vol. II, edited by Colin Lucas, pp. 105123. Oxford, 1988.

Viroli, Maurizio. For Love of Country: An Essay on Patriotism and Nationalism. Oxford, 1995.

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Gail Bossenga

Citizenship: Overview

views updated May 08 2018

Citizenship: Overview

Citizenship consists in sharing a political community, and enjoying the benefits and assuming the political responsibilities that give effect to this experience of shared political community. If the purpose of political philosophy is to provide a principled account of the nature and appropriate boundaries of political community, then it makes sense to say that the tradition of political philosophy from Aristotle to the present is more or less defined by a tradition of reflection on the normative foundations of citizenship. In an important sense, then, the whole history of political philosophy offers a continuing reflection on and dialogue about the nature of citizenship, and it is not clear that one can give a full report on the history of reflection about citizenship with anything less than a thorough and comprehensive account of the history of political philosophy in its totality. This is impossible here, and therefore a short summary of basic themes in the tradition of political philosophy, and its relation to thinking concerning the meaning of citizenship, will have to suffice.

Citizenship in the History of Political Philosophy

Book three of The Politics by Aristotle (384322 b.c.e.) is the first treatise on citizenship, and it remains an essential reference point for all subsequent reflection on what it means to be a citizen: "The citizen in an unqualified sense is defined by no other thing so much as by sharing in decision and office. Who ever is entitled to participate in an office involving deliberation or decision is a citizen in this city; and the city is the multitude of such persons that is adequate with a view to a self-sufficient life" (p. 87). Aristotle's definition of citizenship sounds modest enough, but in fact it encapsulates an awesomely ambitious account of what is required in order for human nature truly to flourish. Aristotle's account of what it means to be a citizen is intended to be a conceptualization of the experience of free, native-born males in the polis as a unique site for the development of properly human capacities. What the definition affirms is that only a very small number of human beings in the history of humankind (and only a minority of the inhabitants of Athens even during the age of the polis) have been in a position to realize their full humanity because they happen to be members of the kind of political community that uniquely gives play to their properly human (political or polis-based) capacities.

In republican Rome the idea of citizen virtue was detached from the robust theory of moral development offered by Aristotle, and saw its crowning ideal in a practice of courageous military heroism in defense of the free state. Still, the Roman drive for glory, honor, and power to defend the liberties of collective, aristocratic self-rule was regarded as double-edged by one of the great Christian fathers, St. Augustine of Hippo (354430). While praising the Romans in his City of God for such a long-lasting and glorious state, Augustine called upon Christian believers (and those who felt themselves to be future citizens of heaven) to recognize the pride residing in these Roman ideals of citizenship, and to see the ultimate futility of all earthly ambitions. Christians, as pilgrims in this world, should adopt a stance of submission, disengaging themselves from the ideals of active participation. Augustine saw in the ultimate failure of human enterprises an opportunity to cultivate humility and acceptance of God's will.

It has long been thought that, following Augustine, the ideals of citizenship were largely absent from medieval thinking and only reappeared in the Western tradition in the Italian Renaissance. However, more recent research has shown the deep historical roots of the links between the language of citizenship and the struggle for communal independence throughout Europe (see Höfert). The lingering presence of Roman law, along with the emergence of a class of burghers who sought new forms of political influence, gave rise to political struggles in which the language of citizenship became, once again, salient.

Niccolò Machiavelli (14691527), particularly in his Discourses on Livy, is regarded as the most famousas well as the most controversialdefender of citizen liberties. Inspired by the ideal of civic virtue as practiced by the Romans, he called for a new ethos of devotion to the political community sealed by a practice of collective self-rule and self-defense. Needless to say, Machiavelli's conception of the citizen-body remains emphatically patriarchal, as is the case, with rare exceptions, for the entire political theory tradition until recent times. Understanding of the internal and external challenges to the survival of the free state led him to recognize that the duties of successful leadership of a free state would necessitate actions that would, at times, contravene the precepts of conventional morality. Nonetheless, he praised republics over principalities, for it was only through collective self-rule that the greatest number could guarantee their personal autonomy and independence and thereby achieve a more lasting and glorious state.

Post-Reformation religious struggles in Europe gave rise to new accounts of the proper relation between rulers and their peoples, especially in matters of religious practice. While these debates were initially more relevant to individuals as subjects of absolute rulers, they brought about broader reflection on the concept of natural individual rights, which would later become a powerful tool in the struggle against absolutist rule. The Second Treatise of Government, by John Locke (16321704), is the best-known account, harnessing the idea of individual rights to a notion of collective sovereignty even though Locke does not reject monarchy. Still, with the advent of commercial society, the possibility of fusing the promotion of individual liberties with a form of government that would require very limited participation on the part of all citizens was increasingly regarded as an attractive alternative. It has meant that in the modern era the quality of citizenship has often been judged more by the accountability of liberal democratic governments toward their citizenry than by the actual forms and degrees of popular participation. But this new synthesis has not been without its critics: modern theorists, notably Jean-Jacques Rousseau (17121778), have drawn on more ancient accounts of citizen virtue to decry the lack of active participation in collective self-rule as an ongoing assault upon true popular liberties.

On the Social Contract, by Rousseau, and The Philosophy of Right, by Georg Wilhelm Friedrich Hegel (17701831), remain the two most important modern treatises on citizenship. At the core of Rousseau's political philosophy is the idea that modern human beings should be judged by the (suitably high) standard of the ancient experience of citizenship. When Rousseau claims, in a note to Social Contract (Book one, chap. 6), that modern men know only what it means to be bourgeois and have no notion of what it means to be a citoyen (citizen), he makes perfectly clear how deficient he regards modern human beings in relation to this standard. This celebration (mythicization?) of ancient citizenship has of course not gone uncontested within modern political thought: just as Rousseau challenged the Lockean synthesis outlined above, so Rousseau's account of citizenship in turn was challenged vigorously by subsequent liberals. Hence it has been one of the chief theoretical purposes defining liberal political theory going back to Charles de Montesquieu (16891755)or perhaps going back to Thomas Hobbes (15881679) if one considers Hobbes part of the liberal traditionprecisely to challenge the normative superiority of classical republicanism. This has been nicely summarized by J. G. A. Pocock: "[Thinkers such as Montesquieu, David Hume (17111776), and Adam Smith (17231790)] argued that the virtuous man of antiquity was obliged by the lack of a free market to live off the labour of slaves who worked his land and gave him the leisure to serve the republic. His 'virtue' made him harsh and barbaric; even his moral personality was impoverished by his inability to exchange goods with his fellows. [With the development of the market, the] rigid and fragile virtue of antique man was replaced by the greater flexibility of 'manners'" (Pocock, p. xxi). Hegel, with his huge debt to the vindication of modernity contained in the classical political economy tradition (see Plant), represents perhaps the crowning expression of the thought that citizenship in the modern liberal state cannot be exhausted by the notion of citizens unwaveringly committed to the exertions of civic virtue. Hegel, in common with other liberals, believed that consciousness of rightful membership in the modern state must incorporate a clear acknowledgment of the legitimacy and, indeed, moral necessity of the energies that individuals invest in their private lives.

Reading Rousseau gives one the impression that the most powerful theorizing about citizenship is located outside of, and in polemical opposition to, the liberal tradition. But students of the history of political philosophy should never forget that there is at the same time a decisively important tradition of reflection about citizenship and civic virtue within liberalism. Alexis de Tocqueville (18051859) and John Stuart Mill (18061873) are two great exemplars of civic theorizing within the liberal tradition. For all Mill's apprehensions about an unrestricted franchise, and for all Tocqueville's anxieties about the unwelcome consequences of the culture of democracy, both of them were strongly committed to enhancing the civic dimension of liberalism, and in that sense, both are important modern theorists of citizenship.

Citizenship in Contemporary Debates

Not surprisingly, the problem of citizenship has continued to shape contemporary debates in political philosophy. Communitarianism, at least as expressed in the work of Charles Taylor and Michael Sandel, presented itself as a new vocabulary for articulating an old complaint about the attenuated character of liberal citizenship. (This is emphatically not the case with the communitarianism of Alasdair MacIntyre, who fundamentally rejects modern nation-state-based citizenship as a site for moral community.) In the case of Sandel, for example, the more he has continued to develop his theoretical concerns, the clearer it has become that his real concern is not with community per se, but rather with the eclipse of richer possibilities of civic engagement and civic identity in an age dominated by liberal-proceduralist conceptions of politics. This basically civic-republican critique of liberalism should be set within a broader resurgence of civic-republican theorizing. Civic republicanism has surged back to life, philosophically, in the influential work of Hannah Arendt and, in a more historical vein, in the work of John Pocock, Quentin Skinner, and Philip Pettit.

More recently, new challenges to liberal citizenship have arisen in the debates about feminism and multiculturalism. As regards the latter, important arguments have been mounted to the effect that civic norms defined within the horizon of liberalism cannot do justice to the profound forms of cultural diversity ("deep diversity") that characterize virtually all political communities today. The basic multiculturalist idea is that liberal societies cannot fully honor the citizenship of their members if essential aspects of the identity of those members are slighted or treated as irrelevant to citizenship. Like any doctrine in political theory, multiculturalism comes in strikingly different versions. In Iris Young's view, liberal citizenship must be radically reconstructed so as to acknowledge an emphatic "politics of difference." In Will Kymlicka's more moderate view, accommodations to cultural difference are themselves required by liberal justice, rightly understood. According to the latter view, multiculturalism is merely a more effective (and more just) vehicle for the integration of minorities into a liberal civic regime, whereas according to the former view, the liberal vision of citizenship is intrinsically flawed, since liberal universalism is simply a mask for the hegemony of a majority culture.

At the same time, one can say that the powerful challenges to liberal understandings of citizenship generated by communitarian, civic-republican, and multiculturalist theorists have provoked, in response, more robust and more philosophical theories of citizenship from the liberal side. Jürgen Habermas's theory of communicative action can be interpreted as a new liberal (or post-liberal) doctrine of citizenship, and John Rawls's ambitious meditation on the notion of "public reason" in the latter phase of his intellectual career offers another such doctrine. The fundamental issue is posed by Rawls in relation to what he calls "civic humanism" ("classical republicanism" he regards as a more modest doctrine): "[Civic humanists believe that] the activity in which human beings achieve their fullest realization, their greatest good, is in the activities of political life. [Liberal justice as Rawls understands it] rejects any such declaration; and to make the good of civil society subordinate to that of public life it views as mistaken" (Rawls, pp. 420421; cf. pp. 205206).

The opposing side is represented by Hannah Arendt when, at the conclusion of On Revolution, she endorses the ancient Greek solution to the problem, posed by Sophocles, of how "to bear life's burden": "It was the polis, the space of men's free deeds and living words, which could endow life with splendor" (Arendt, p. 285). The issue here, as it was originally in Aristotle's doctrine of citizenship, is whether civic life constitutes a privileged location for the expression of our proper humanity, or whether it ought merely to furnish a procedural framework for more diverse, privately defined activities in which we express our humanity. So we see that one of the core debates that has animated political philosophy throughout its historyfor instance, in the argument between Rousseau, with his uncompromising republicanism, and his liberal critics such as Adam Smith (see Ignatieff) and Benjamin Constant (17671830)continues to be a living question in contemporary thought.

See also Civil Society ; Democracy ; Nation ; Political, The ; Social Contract .


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Aristotle. The Politics. Translated by Carnes Lord. Chicago: University of Chicago Press, 1984.

Beiner, Ronald, ed. Theorizing Citizenship. Albany: State University of New York Press, 1995.

Hegel, G. W. F. Elements of the Philosophy of Right. Edited by Allen W. Wood. Translated by H. B. Nisbet. Cambridge, U.K.: Cambridge University Press, 1991.

Höfert, Almut. "States, Cities, and Citizens in the Later Middle Ages." In States and Citizens: History, Theory, Prospects, edited by Quentin Skinner and Bo Stråth, 6375. Cambridge, U.K.: Cambridge University Press, 2003.

Ignatieff, Michael. The Needs of Strangers: An Essay on Privacy, Solidarity, and the Politics of Being Human. New York: Viking, 1984. See chapter four.

Machiavelli, Niccolò. Discourses on Livy. Translated by Harvey C. Mansfield and Nathan Tarcov. Chicago: University of Chicago Press, 1996.

Plant, Raymond. "Hegel and Political Economy." New Left Review no. 103 (May/June 1977) and no. 104 (July/August 1977).

Pocock, J. G. A. "Introduction." In Edmund Burke, Reflections on the Revolution in France. Indianapolis: Hackett, 1987.

Rawls, John. Political Liberalism. New York: Columbia University Press, 1993.

Riesenberg, Peter. Citizenship in the Western Tradition: Plato to Rousseau. Chapel Hill: University of North Carolina Press, 1992.

Rousseau, Jean-Jacques. On the Social Contract. Edited by Roger D. Masters. Translated by Judith R. Masters. New York: St. Martin's, 1978.

Juan GÓmez-QuiÑones

Born of Mexican parents in 1940 in Parral, Chihuahua, Juan Gómez-Quiñones has been active in the articulation and political negotiation of cultural citizenship since the 1960s. His experience in the United States' Chicano civil rights movement led to his authoring of foundational papers on the history and identity of Chicano peoples of the southwestern United States. Soon after, he expressed the importance of and developed an epistemology for Chicano studies as a new interdisciplinary field. Such efforts helped to establish Chicano studies in institutions of higher education throughout the nation. Among his published works are Chicano Politics: Reality and Promise, 19401990 (1990); Mexican American Labor, 17901990 (1994); and Roots of Chicano Politics, 16001940 (1994). In 1971 he helped found Aztlan: International Journal of Chicano Studies Research, the United States' premier journal of Chicana and Chicano studies. He is professor of history at the University of California at Los Angeles (UCLA) and lives with his family in Santa Monica, California. In 2003 UCLA presented him with the Rosenfield Distinguished Community Partnership Prize for community service.

Ronald Beiner

Rebecca Kingston


views updated May 14 2018



The construction of Europe as a political entity started immediately after World War II, motivated by the belief that only creation of a genuinely European citizenship would put a definitive end to the violence and atrocities that had ravaged the old continent throughout its history. As of 2005 the European Union (EU) included twenty-five nations that maintain peaceful relations among themselves. Europe has thus attained the first and principal objective of its foundational figures. However, a consensus exists that the EU has not yet become a real political community. Most of its inhabitants do not consider themselves "citizens of Europe." A major reason for this is the fact that the leaders of the principal member-states do not always agree on the type of citizenship to be promulgated. Since the nineteenth century, each nation has developed differently and created its own definition of citizenship. The past still weighs on the present, obstructing reflection and action on the part of those who militate on behalf of a politically unified Europe.


World War I may be considered a turning point in the history of European citizenship. In destroying the old empires and consolidating the ascendancy of nation-states, it represented the beginning of the new era. But the war also marked the outcome of a long historical process that occupied peoples and nations during the nineteenth century. During the nineteenth century, indeed, each nation created its own vocabulary to express the concept. To translate the English word citizenship, French offers a choice of two words: citoyenneté and nationalité. The same is true for the German language, with Bürgerschaft and Staatsangehörigkeit. Like other Latin languages, French uses nationalité to designate both the common origin of inhabitants and the concept of state affiliation, while English and German employ two different terms to more clearly differentiate these two notions.

The history of nations explains these linguistic differences. In England, the wealthy landowners, in contesting the arbitrary character of the monarchy, had obtained the right to appoint their parliamentary representatives. In that country, the concept of citizenship was associated from the start with defense of individual liberties and with obtaining new rights, but it did not call into question the oath of allegiance of the "subjects of His Majesty." With reference to this specific case in Citizenship and Social Class (1950), the political scientist Thomas Humphrey Marshall (1893–1981) proposed a definition that remains famous and is still discussed in textbooks in the early twenty-first century. Emphasizing the gradual enlargement of rights granted to citizens, he suggested that in the wake of the civil and political rights obtained during the eighteenth and nineteenth centuries, the second part of the twentieth century marked the start of a new phase, based on the emergence of social rights granted by the welfare state.

Marshall's view, however, did not take into account individual histories of the other major European states. The French definition of citizenship was profoundly influenced by the Revolution of 1789. In that country Jean-Jacques Rousseau's (1712–1778) conception prevailed. In his Contrat social (Social contract) in 1762, Rousseau criticized the English for not sufficiently or carefully enough separating political and civil rights. Taking Athens as his model, Rousseau believed that citizenship should be defined by active participation in the life of the state. He advocated replacing monarchies with republics that were defined as sovereign communities, the members of which submit to the laws of the state, as subjects, but also as citizens who collectively contribute to the development of laws and legislation. Rousseau's influence explains why the French often approached the concept of citizenship from the perspective of participation in the nation's political life, and for a long time they were preoccupied with determining who should belong to this civic community and who must be excluded. The struggles of workers' movements and feminists to extend the right to vote to the lower classes and to women should be viewed in this context.

History also explains the distinctive vocabulary for German citizenship. While in France and England the monarchic state had imposed sovereign power over all its subjects since the seventeenth century, the German Holy Roman Empire, first adumbrated by Charlemagne (r. 768–814), had collapsed in the Middle Ages, leading to a multitude of separate states and principalities. In this context, the monarchic state's first priority was to impose its law upon all its subjects. This was why the Prussian king, Frederick William II (r. 1786–1797), enforced the Allgemeines Landrecht (General State Law) in 1794. The nobility consented to obey this code but, in exchange, the king acknowledged they enjoyed privileges and continued to place heavy burdens on the peasants. Principles of citizenship such as individual liberty and equality, as a consequence, took hold only slowly in the German states. The bourgeoisie, as the class that included individuals who benefited from the droit de cité, or citizenship rights accorded city-dwellers, played a major role in this emancipation process. It is no accident that German is the only European language in which the terms for citizen and bourgeois are virtually synonyms.

In the early years of the nineteenth century the German vocabulary for citizenship acquired a new word, Volkstum. Philosophers, who were intellectuals drawn mostly from the upper class, had greeted the French Revolution in 1789 with enthusiasm. However, occupation of German territories by Napoleon's army forced the Germans to revolt against French domination. From that point on the battle for freedom was no longer a struggle against an arbitrary power and privileged class (the nobility), but also a fight to emancipate an oppressed nation. Henceforth it was not enough to know who was a citizen and who was not. Nations must now define themselves and set out criteria by which they could be identified and distinguished each from the another. One fruit of this effort was Volkstum, a word invented by the philosopher Friedrich Ludwig Jahn (1778–1852) to designate the "national character" of a people by applying three criteria—language, custom, and, most important of all, "the vital impulse," defined as the "spiritual principle" that stamps a nation as unique. French writers and historians of the Romantic period (1820–1840) agreed with and endorsed this definition. They translated Volkstum with a new French word, nationalité, in hopes of clarifying France's own particular characteristics.

During this period the "principle of nationality" became popular throughout Europe. It legitimized the struggles for national sovereignty for which small groups of militants were fighting. The defeat of the Revolutions of 1848 brought about brutal repression of these subversive movements. But they continued to gather strength in the decades that followed, attacking the power of old empires from within. This would be one of the chief causes of World War I.

At this time, in the German language, another word, Staatsangehörigkeit, appeared; it designated citizenship not by allegiance to a nation but rather to a state. Prussian civil servants first employed the term in the context of arguments with neighboring countries concerning measures to control vagrancy and begging. The Prussian state, wishing to care only for its own poor, passed a law in 1842 that more clearly defined which individuals would benefit from its protection. The law specified that the legal status of the Prussian subject was transmitted by paternity from father to child. Thus, Prussia relied on the jus sanguinis (right of blood), which had been used in 1804 by the Napoleonic Civil Code to specify French status and which was later adopted by most European countries. The noteworthy exception was England; that country remained faithful to the feudal principle of the jus soli (right of territory), by which birth within a state confers nationality.


Until the end of the nineteenth century citizenship and nationality were viewed from two different angles. Philosophers and political activists were principally concerned with what it meant to belong to a nation or a people, while magistrates and bureaucrats were interested in the problem of who belongs to a state. The years between 1880 and 1914 were a vital period in the history of citizenship because these two concerns were ever more closely linked. Workers gradually won the right to vote and various social rights. But, at the same time, governments obliged citizens to enlist in the military and do battle for their nation.

Given these circumstances, one can understand why the right to citizenship became a major political issue. Increasing migration and a terrible economic depression beginning in the mid-1870s provoked the government to intervene in social matters. Most European countries passed laws on immigration and citizenship that revealed a protectionist impulse in public policy-making. Such laws established strict lines of demarcation that separated nationals, who benefited from them, and foreigners, who did not. Citizenship laws also enabled nations to increase their populations by turning foreigners into citizens by a wave of a judicial magic wand. At a time when a nation's power was still measured by the number of soldiers it could enlist in its military, no state was prepared to deprive itself of this resource. By contrast, because leaders were ever more concerned by citizens' loyalty to their nation, the right of citizenship also functioned to exclude those suspected of not sharing the feeling that they belonged to the national community.

These new laws regarding citizenship, which would remain in force through the rest of the twentieth century, must be above all understood as instruments in the service of state power. Arguments used to justify them were often found in the writings of philosophers and historians. But governments used such arguments only if they served their interests. The case of Switzerland clearly revealed that linguistic or religious criteria were not employed to define citizenship when the powers that be judged them inopportune. The notion of "Swiss citizenship" entered the legal vocabulary during a constitutional revision in 1874. From that point on, only the Helvetian confederation could decide on the rules pertaining to political and civic matters insofar as they applied to the Swiss themselves. However, the droit de cité communal, a retention from the ancien régime, remained a determining factor in acquiring citizenship. Anyone who did not enjoy its privileges was considered a "stateless person" (heimatlose).

The major issue that brought about citizenship reform in France in 1889 was concern over the declining birthrate. Since the 1860s France has been a destination for immigrants. The republican regime wanted to avoid the formation of ethnic minorities; the army needed new soldiers. In Algeria French colons wished to reinforce discrimination against the local population but they also wanted to prevent Italian and Spanish immigrants from becoming a majority. This led the government to grant greater importance to the droit du sol (citizenship for all those born on French soil with at least one parent born in France) as a way to convert those born on national soil into French citizens.

Germany was unique in that it was a destination for immigrants, including a large Polish community in eastern Prussia, and at the same time a country of emigration, with some 3.5 million Germans in other countries. The main goal of the German citizenship law voted in 1913, known as the Delbrück Law, was to reinforce the bond of nationality beyond the country's borders. Individuals born of German parents were to be considered German citizens. Contrary to what was often claimed, such a reinforcement of the jus sanguinis did not represent the wish to apply a "German conception" of the nation. Rather, the law aimed to better protect the interests of a country losing inhabitants to emigration at a moment when receiving countries were striving to "nationalize" the foreign population within their borders. In 1891, for example, Brazil decided that all immigrants living on its soil were henceforth Brazilian citizens, unless they expressed the wish to retain their former nationality. As early as 1912 Italy also reinforced the jus sanguinis, allowing all native Italians living abroad to retain their original citizenship.

The legal status of individuals thus became, during the years preceding World War I, a central issue that constituted a form of rivalry among nations. These laws not only demarcated a rigid boundary between the national and foreign populations but also fomented discrimination within the national population as a whole by establishing a variety of intermediate categories of individuals who were denied full citizenship, such as women, stateless persons, naturalized citizens, natives of the colonies, and others.

Another reason that right of citizenship became a major problem was that the fact of belonging to a nation was not only a judicial issue. During this period bureaucracy had made major strides. The state intruded ever more deeply into all the spheres of daily life of its citizens. Everywhere in Europe bureaucrats accomplished the huge task of creating systems of identification and thorough and precise registers of citizenship. This was the era that saw the first modern identity papers and population census reports, from which statistics could be extracted and maps created to reveal the ethnic composition and distribution of the populations.


During World War I citizenship and nationality were connected in a highly repressive way. Passage of the Delbrück Law a few months before hostilities began was perceived in France and England as a warlike act that aimed to destabilize other European countries by seeking support from German and Austro-Hungarian immigrants. This was the reason why, with the beginning of the war, foreign nationals from those countries were confined in internment camps. Similarly, the Allies adopted laws refusing citizenship to immigrants from enemy countries. These decisions, justified by the war, remained in force during the next several decades. In France the law of denaturalization would later be used against previously naturalized communist activists. Internment would also be applied during World War II, including the detention of Germans fleeing Nazi persecution.

In 1854, at the time of the Crimean War, Napoleon III (r. 1852–1870) had refused to imprison the numerous Russians then living in France, contending that he was at war with princes, not people. This kind of reasoning could no longer apply after the principles of citizenship were established because each citizen is considered a representative of his or her nation. After World War I this logic spread to the whole of Europe. It is estimated that the peace treaties signed in 1919–1920 affected the citizenship of about one hundred million individuals. A change of such magnitude had not occurred since the Napoleonic era. "Peoples' right to self-determination," officially proclaimed in January 1918 by U.S. president Woodrow Wilson (1856–1924), became a bedrock of international law. In the name of the "principle of nationalities," the great powers became the supreme arbitrators for determining which groups "really" constituted a nation and which did not, based on ethnic, linguistic, or religious criteria—which, in fact, those nations had never themselves respected in the course of their own histories. Considering the extraordinary diversity of populations living in eastern Europe and the Balkans, these criteria could only be applied in an arbitrary way. Groups that could not obtain the status of sovereign nation became "minorities" with rights guaranteed by the League of Nations, but the new nation-states considered them to be threats to their integrity. The principle of national homogeneity, legitimized by the great powers, fueled tensions that led to armed conflicts, notably between Greece and Turkey in 1919–1922. Massive population transfers occurred in the Balkans and in Asia and were most often enforced without taking into account the will of those involved.

The totalitarian parties that came to power between the two world wars followed to extremes the logic of belonging to a state and the concept of national homogeneity that had been created in the nineteenth century. The Bolsheviks, Italian Fascists, and Nazis each adopted laws of denationalization to be used against enemies of the regime. In Germany laws depriving Jews of the protection of the German state created a "legal" framework for the persecutions and thereby inaugurated a process that led to the Holocaust. Unlike British or French legislation that applied only to individuals guilty of treason, the Nazi laws were applied collectively and based on racist criteria that principally targeted Jews. The Reich Citizenship Law of 15 September 1939 stipulated that henceforth only nationals of "German blood" were to be considered citizens of the Reich. Anti-Semitic laws adopted in France by the Vichy government during World War II employed the same logic. Similarly, totalitarian regimes justified massive population transfers with arguments about homogeneity of the peoples as an extension of the principle of nationalities. This was why, as the historian Eric Hobsbawm has emphasized, Adolf Hitler (1889–1945) was a "Wilsonian nationalist" when he organized the transfer of Germans living abroad to Germany as well as when he decided to eliminate the Jews. Nevertheless, one must not forget that the Allies stood up for "peoples' right to self-determination" as a means to favor peace and put an end to ethnic clashes, while the Nazi regime applied its policies of homogeneity to physically eliminate millions of people.

What made the Stalinist Soviet Union unique with regard to the physical extermination of civilians was its supposed universal destiny and project for constructing a worker's state. Social and economic arguments, rather than ethnic categories, were used to justify mass repression, such as the elimination of the kulaks (wealthy peasants). The fifteen republics that constituted the Soviet Union represented as many "nations," each with its own territory, language and, at least in theory, a significant measure of autonomy. After 1932 nationality defined in ethnocultural terms became an element in the personal identity of everyone in the Soviet Union, and was duly so registered by official census reports. This institutionalization of nationality would seriously fuel the violence that erupted after the collapse of the Soviet regime in the early 1990s. The same process could be observed in other communist countries, notably in Yugoslavia.


The establishment of principles of national citizenship thus may be viewed as a series of missteps that in a sense facilitated the tragic paroxysms of Nazi barbarism and the horror of World War II. As soon as peace returned, consequently, there were numerous international initiatives to establish durable and definitively pacific relations between peoples. The Universal Declaration of Human Rights, adopted by the United Nations in 1948, is among the most appealing demonstrations of this collective effort to support the emergence of a universal citizenship. Establishment of the European Union was undertaken with the same basic rationale, even though the various nations did not renounce their sovereignty. On the contrary, it is most striking that postwar citizenship laws adopted by the European states extended their own traditions. The West Germans continued to abide by the Delbrück Law and by the jus sanguinis, because, according to them, inhabitants were still Germans even if living in another sovereign land. In the same way, the United Kingdom retained the right of soil and all people within the empire were granted Britain citizenship and were subjects of the Crown. France, which became one of the principal destinations for immigrants between the two world wars, reinforced the principles built into its 1889 citizenship law.

However, in the postwar decades, citizenship legislation in the various European nations gradually converged. Two reasons explain this phenomenon. The first involved the integration of nations in the European Union. This was accomplished, to be sure, more by creating a large common market than by the construction of a genuine political union. However, elimination of the customs duties was one step in a process that finally enabled people to circulate freely within the European Union—a decision taken by the several states that signed the Schengen treaty in Luxembourg in 1985. Borders separating nations now designated their interior limits while the real boundaries that protect European space moved to the perimeter of the Union. European citizenship was reinforced in 1992 by the Maastricht Treaty, signed in the Netherlands, which granted citizens of one EU nation the right to live and work in another member nation, and in certain cases even vote in local elections. Another essential element in the process of integration was the adoption of a single currency in 2002. Money had long been a fundamental component of state sovereignty and an essential factor in identifying citizens as belonging to a specific national community. The relative ease with which Europeans accepted the euro was a genuine victory over the past. The final element in the progress of European citizenship concerns the judicial and administrative spheres. Even if unaware of it, Europeans in the early twenty-first century abide by laws that were established, in most cases, by high-ranking civil servants of the European Commission in Brussels, by elected members of the European Parliament in Strasbourg, and by members of the Court of Justice in Luxembourg.

However, until the beginning of the twenty-first century, it has not been possible to create a common accord that would regulate European citizenship. Not all authors agree as to the reasons for this stumbling block. Many think that citizenship expresses one's national identity, so that the past still weighs too heavily on the present to allow the major European states to agree, now or in a near future. But other researchers, on the contrary, believe that nothing, in principle, should prevent a unified law of citizenship. Most European nations have become destination countries for immigrants. However, in the modern world, governments cannot allow the constant multiplication, generation after generation, of great numbers of individuals who do not "belong" to their nations. Since the 1970s most European governments have thus modified their right to citizenship in a way that most resembled the system that France, the oldest of the immigrant-destination nations, adopted at the end of the nineteenth century. This system, while based on the jus sanguinis, still leaves an important place to the jus soli, which allows the immigrants' children to join the national community. Since World War II the Netherlands, Belgium, and Spain have legislated measures along these lines.

But the growing convergence of European law around citizenship is exemplified by the legislation Germany adopted in 1999. The Germans now made a place for the droit du sol. The British response represents rapprochement of a different kind. As noted, traditionally, the right of citizenship in England was based on the subjects' oath of allegiance to their monarchy. Everyone under the jurisdiction of former colonies had, as a consequence, the right to freely inhabit British soil. To gain greater control over African and Asian immigration, however, the government has in recent years modified the law by giving full benefits of citizenship only to British citizens born in the United Kingdom.

In the early twenty-first century, in all nations that comprise the European Union, three categories are distinguished vis-à-vis the right to citizenship: citizens of the various nations, citizens of Europe, and non-Europeans.

See alsoEuropean Union; France; Germany; Holocaust; Immigration and Internal Migration; Maastricht, Treaty of; Minority Rights; Soviet Union; Switzerland; United Kingdom; World War I; World War II.


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Arlettaz, Gerald, and Silvia Arlettaz. La Suisse et ses étrangers: Immigration et formation nationale, 1848–1933. Lausanne, 2004.

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Cafruny, Alan, and Glenda Rosenthal, eds. The Maastricht Debates and Beyond. Boulder, Colo., and Burnt Mill, Harlow, U.K., 1993.

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Hobsbawm, E. J. Nations and Nationalism since 1780: Programme, Myth, Reality. Cambridge, U.K., 1990.

Jahn, Friedrich Ludwig. Deutsches Volksthum. 1810. Hildesheim, Germany, and New York, 1980.

Klausen, Jytte, and Louise A. Tilly, eds. European Integration in Social and Historical Perspective: 1850 to the Present. Lanham, Md., 1997.

Kocka, Jürgen, and Allan Mitchell, eds. Bourgeois Society in Nineteenth-century Europe. Oxford, U.K., and Providence, R.I., 1993.

Koselleck Reinhart. Futures Past: On the Semantics of Historical Time. New York, 2004.

Lucassen, Jan. Migrant Labour in Europe, 1600–1900: The Drift to the North Sea. London and Wolfeboro, N.H., 1987.

Marshall, Thomas Humphrey. Citizenship and Social Class and Other Essays. Cambridge, U.K., 1950.

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GÉrard Noiriel


views updated May 29 2018


definition of citizenship
the role of revolution
inequality and citizenship
citizenry and state authority

The concept of citizenship claims a venerable intellectual tradition. The lived history of modern citizenship, however, was born in conflict and revolution. In June 1789, when the French Estates-General reseated itself—not as the three estates of the land but as the National Assembly—and proclaimed that it would not disband until it had written a constitution for the French nation, the delegates in Versailles had declared themselves citizens. Their right to form a new government, a new covenant between themselves, stemmed from universalist principles of natural law and freedoms inherent in their humanity. In making revolution, Abbé Emmanuel Sieyés explained, the people reclaimed their sovereignty from absolutist monarchy and set forth to remake state power in their own image. By placing popular sovereignty at the center of the exercise of power, this profound transformation of political personae from subjects of royal power to self-actualized citizenry stirred hopes and fears that shaped politics and state boundaries for the next century.

definition of citizenship

The French Revolution of 1789 may have fused popular sovereignty and nationhood as powerful philosophical abstractions, but what did it mean when men and women addressed each other as citoyens and citoyennes? Scholars have helpfully distinguished between seventeenth-century natural law arguments, which that established the discourse of rights protecting individual liberties from state incursions, from the older tradition drawn from Athenian civic republicanism that emphasized individual virtue along with the duties and obligations of belonging. While analytically important in understanding political discourse, most working models of participatory government mix the two, balancing the negative expressions of rights (the delimitations of state power) with positive assertions of membership (also conceived of as rights) that name the entitlements and responsibilities of inclusion.

In the juncture of events during the French Revolution, however, the process of limiting royal power also exposed unbridgeable disputes over the purposes of good government and the nature of representation, particularly as they addressed popular participation and the welfare of the people. Thus when Louis XVI withdrew his grudging support of constitutional monarchy and appealed ineffectively to royalists within and outside French borders, the pressures of maintaining the Revolution through internal dissension and external war turned principled disagreements into factional struggles that toppled and led to the convening of many forms of government. Between 1791 and 1815, there were a total of four constitutions, each of which radically restructured the relationship between executive and legislative power and redefined the practical meaning of participation and self-governance.

the role of revolution

Although the Revolution gathered many critics, it also enjoyed avid defenders. From the constitutional monarchy of 1789 to the Jacobin republic of 1792, to emergency wartime rule by the Committee of Public Safety, to the oligarchy of the Directory, and finally to the charismatic authoritarian plebiscite democracy of Napoleon I—each phase of revolutionary development reached across state boundaries to inspire different groups of sympathizers in neighboring territories and across the Channel. Thus when the concert of old European monarchical empires aligned to defeat the French Republic in 1792 and later in 1815 to restore the balance of power among themselves, they quickly realized that the threat to their social and political order was internal as well as external. Although the Congress of Vienna (1814–1815) was supposed to have reestablished autocratic power, in fact, Europe's absolutist rulers mostly understood that old regimes could not be restored without some concessions to participatory government. Balancing their fear of revolution against their anxieties over power sharing, entrenched aristocratic elites made selective accommodations to the upper echelons of non-noble property owners. Hence even in the symbolically freighted restoration of the Bourbons to the French crown, Louis XVIII governed with a charter (the Charter of 1814) that placed constitutional limits on his power and provided an elected chamber, albeit with a highly restrictive franchise that excluded 90 percent of the adult population.

In Great Britain after 1820, the ascendancy of moderate Tories and Whigs pushed through electoral changes resulting in the Reform Act of 1832, which doubled the number of voters among householders and modified the dominance of the landed gentry. Constitutional movements in the southern German states met with equally positive responses. By the early 1820s, the duchies of Nassau and Saxe-Weimar-Eisenach and the kingdoms of Bavaria, Baden, and Wűrttemberg had given themselves written constitutions based on compromises between the old aristocratic order, the crown, and new principles of bourgeois society. Reforms within Prussia had begun before 1815, and even though the constitutional movements associated with Heinrich Friedrich vom Stein and Karl August von Hardenberg failed, reformers succeeded in bringing the bureaucratic state under the rule of law and instituted some safeguards for civil liberties.

Could these autocratic states and limited monarchies have met the participatory desires of its haute bourgeoisie and middle classes without conceding the primacy of their power base and monarchical principles? Each locality, of course, offered its own story, but pragmatic compromises were often eclipsed by the recent memory of revolution. By their example, revolutionaries in France had forever cast aside any belief that patient supplication to sovereign rulers was the only route for attaining political change. Moreover the intellectual culture of the Revolution had drawn conceptual links between various liberal demands, creating a coherent program for change. Hence when liberals thought of themselves as citizens in the post-Revolutionary era, the systemic incompatibility between theories of popular sovereignty and theories of monarchical authority (particularly those of absolutist hereditary rule) reminded them that they lived at odds with the basic political tenets of their society. In such a context, annoyances moved easily to principled opposition.


This revolutionary potential built into liberal aspirations was enhanced by the possibilities of radical alliances. In Paris during the summer of 1830, for example, the more strident agitation of craftsmen, journeymen, university students, and journalists joined with the protest of liberal elites against press censorship and royal usurpations of the Charter of 1814. Their collective power was demonstrated at the barricades when, after only a few days of bloodshed, Charles X abdicated. In the German states, the French Revolution of 1830 reactivated liberal movements that had turned in solace to romantic quests for a pan-German community through spiritual reform and self-improvement (in such associations such as the Turn-Vereins and Burschenshaften). In Munich, Göttingen, Hanover, and Frankfurt, as in Paris, bourgeois and middle-class militants combined with artisans, workers, students, and journalists to organize festivals and political banquets. In the spirit of civil disobedience, they offered toasts, made incendiary speeches, and sang the "Marseillaise."

In the 1830s, state authorities everywhere in central Europe crushed the flowering of rebelliousness before the new popular alliance could be tested. Despite the evident potentials of their combined forces, bourgeois liberalism and radical democracy were fundamentally not alike. They appealed to different conceptions of society and politics. And although they both held that the citizen was sovereign, they differed on who could be a citizen. Within a liberal worldview, only those individuals who were legally free to enter into contracts as self-possessing agents could participate in public life. Conceiving the civic realm as growing out of associational life, self-government among equals meant the setting of common rules as part of the broader protection of individual freedoms. By contrast, radicals often invoked an almost literal understanding of the common body as the basis of collective life, leading to very different descriptions of the bonds between citizens, of mutual obligation, and of equality. Against the barriers established by property qualifications, artisans and the laboring poor claimed that their skills or their labor constituted property. In so doing, they joined other groups who also challenged the liberal definition of the autonomous individual handed down from seventeenth-century theorists, which conceived of personhood not only as inseparable from landed and productive wealth but also in terms of proprietary rights in others: wives, children, servants, and slaves. Thus not surprisingly, the discourses of slave emancipation and feminism shared a common appeal to self-possession as the natural precondition for self-determination and civic participation as equals.

inequality and citizenship

In other respects, however, the deeper challenge faced by these disenfranchised groups against persisting distinctions between "active" and "passive" citizens first introduced in the French Constitution of 1791 centered on the difficult task of redefining "civic virtue." Here the "disqualifications" represented by race and sex take different forms. During the French Revolution and throughout much of the nineteenth century, the exclusion of women from active citizenship as creatures inherently incapable of justice or dispassionate reason was part of the process of defining the public realm as an expression of bourgeois masculinity. Hence, the "impairments" of femaleness named were multiple and contradictory—setting the vindication of feminine capacity and moral rectitude in the following century in often opposing directions. Through the century, feminists maintained their critique of liberal individualism, although the women mobilizing for change demanded both special laws and services that addressed their specific conditions and contributions as women and argued for the irrelevance of bodily distinctions in sharing the rights and entitlements granted to men. Ironically, the long-awaited recognition of women's "worthiness" for citizenship finally came in the twentieth century as the liberal model of citizenry underwent radical transformation at the initiative of state authority.

Contrary to expectations, given the inability to fully integrate citizens of non-European descent in the Europe of the early twenty-first century, racial equality in citizenship was not an empty promise in the French Revolution. The National Assembly recognized and defended the claims of the few colonial mulatto and free black men who fully qualified for the franchise. The more consequential issue came with abolition. In both French and British colonies, the claims and entitlements of former slaves exposed the contradictions of the liberal legacy. Although the course of emancipation took very different routes in the two empires (slavery was abolished in French colonies in 1794, reinstated in 1802, and abolished again in 1848; British abolition was accomplished in 1833), both the French and British colonial administrations framed the question of citizenship for freedmen and -women fully within the problem of managing a potentially disorderly labor force. For abolitionists, the central questions of inclusion and belonging stalled around questions of "worthiness." Discussions of freedom were thus redirected to the questions of tutelage. There, the long probation of blacks became inextricably entwined with congenital interpretations of bodily differences in European science and politics. What might have begun as the prejudices of class centered on the impossibility of those who must labor to claim civic virtue became the indelible disqualifications of phenotype.

These enduring problems of sexism and racism have recast assessments of radical movements for direct democracy in the first half of the nineteenth century. Scholars have mostly interpreted these political programs in light of the social discontents behind protest (poverty, subsistence crises, unemployment), but as the masses mobilized by the People's Charter (1838) in Britain demonstrated, their radical democratic vision did not come primarily from workplace or marketplace struggles (despite the many close connections to Owenite socialism). Rather, the Chartists formulated a populist theory of justice as part of the broader agitation led by the middle classes against the Corn Laws and for extending the franchise. Out of a shared political arena, the Chartists articulated a vision of citizenship distinct from their liberal counterparts. On the Continent, although radical artisans, journeymen, and the laboring poor were influenced by various schools of socialist thought (Saint-Simonians, Fourierists, Louis Blanc, and later Karl Marx, Ferdinand Lassalle, and Pierre-Joseph Proudhon), in France and the German-speaking states where guild traditions were strong, models for participatory democracy often spoke the language of the corporatist tradition mixed with the universalist language of freedom and rights from the French Revolution. Nonetheless, the solidarities of working men typically demanded honor and recognition as men—despite the fact that working women also fought for universal suffrage (before upper-class women mobilized for the equal franchise), salaried elected representatives, and collective responsibility for the livelihood of the poor. Working women readily mounted to the barricades to demand price maximums on subsistence goods and national workshops to redress unemployment in female-dominated trades. Similarly, although socialist rhetoric was internationalist, working men organized within national political boundaries and conceived of politics from within national traditions. Support for abolition (especially among the Chartists) and fleeting expressions of solidarity aside, few nineteenth-century radicals thought systemically about the possible connections and commonalities between colonial subjects and the European poor. Yet from the perspective of political economy, the theory of wage labor as free labor was conceived at the point at which colonial and metropolitan economies joined.

citizenry and state authority

Despite the limits of masculinist and nationalist blinders, class-based analysis and alliances remain significant in comprehending the revolutions that swept across the continent again in 1848. The near victories but ultimate defeats of liberalism and republicanism brought out the familiar refrain that the bourgeoisie had preferred to compromise with autocratic power rather than to risk threats from below. Whether one believed that the temporary triumph of antidemocratic forces was the result of betrayal or cowardice, certainly the arrest and deportation of radicals marked a dramatic setback for all populist causes. At midcentury, European politics was dominated by the territorial conquests and limited wars of German and Italian unification. But looking beyond the changing European balance of power to the domestic policies of empire/nation building, one sees that revolution and popular sovereignty still preoccupied the politics of reaction. For example, the new constitution for the German Empire granted universal male suffrage but negated the power of the vote by denying any real decision-making power to the federal representative body. While the Reichstag nominally held the purse strings, the crown retained its independence because the military and the foreign office remained constitutionally under the control of the emperor and his chancellor. But even such structural guarantees were not enough. The preservation of the old landed and military elites ultimately depended on Otto von Bismarck's ability to manage the new sources of social power emerging from a rapidly industrializing empire. Here, the German chancellor's innovations both transformed the nature of autocracy and remade civil society. While the empire prohibited the independent self-organization of industrialists, middle-class professionals, workers, peasants, Catholics, and others, Bismarck wooed each group with specially targeted benefits. The results were often unexpected. For example, the much more politically conservative German Empire was far ahead of Britain and France in providing state-sponsored insurance and old-age pensions for the working classes. But, at the same time, the German Social Democratic Party, the largest socialist party in Europe, was outlawed.

By recognizing that citizens had claims on the state, modern autocratic states further shifted the power relations between state and citizenry in favor of state authority—not only through repression or usurpations but also by ascribing new responsibilities to itself and cultivating new clients. While such expansions of state power may seem unremarkable within an existing autocratic structure, parallel patterns—those emerging in late Victorian Britain and the French Third Republic as parliamentary politics stabilized through the disciplining practices of new political parties—are noteworthy. By the early twentieth century, the prevailing wisdom in the competitive system of European nation-states was that their very modernity rested on an effective compromise between enlightened statecraft from above and populist nationalism from below. To the degree that bureaucratic organizations needed popular mandates to effectively harness the nation's productive and reproductive power, to build military might, and to garner international respect, citizens as entitled subjects of state power also gained many benefits through public resources. As the sociologist T. H. Marshall would later theorize in the middle of the twentieth century, but that European states had already begun to put into practice decades earlier, a comprehensive population policy covering health, education, housing, and old age attached to the entitlements of citizenship promoted new understandings of social progress and equality. But such policies also empowered bureaucracies as the guarantors of rights and entitlements. While the rules therein were open to legislative and procedural change, the expansion of state power was unmistakable. Even in moments of popular protest and discontent, the state remained the object of petition and the source of recognition.


Taking the century-long view then, one is tempted to ask: Is the history of citizenship between 1789 and 1914 the story of its containment and management? Ideologically, "the people" have become indispensable. But once their consent has been mobilized, they become marginal to the everyday tasks of governing. Could the much-touted final triumph of liberalism in the parliamentary democracies of western Europe at the end of the century be said to be the result of the conscious demobilization of citizenry through the routinization of politics? While popular sovereignty may be both the victim as well as the spark that ignited the anguished transformation of political power from absolutist monarchies to modern nation-states, the evocative power of citizenship even as abstract principle has continued to mobilize hope. In the twentieth century when centralized power has collapsed in wartime and other severe political crises, such as between 1917 through the mid-1920s and immediately after 1945, citizens in neighborhoods, union halls, and even soldiers' barracks have readily claimed collective self-rule. In the early twenty-first century, as new groups bring their aspirations for inclusion and belonging, the utopian appeal of the concept of citizenship invites mobilizations fueled by desires that are difficult to extinguish. There thus remains an "unruly" promise in the vision of citizenship first announced in eighteenth-century revolutions that seems always to exceed the limits of received politics.

See alsoMinorities; Nationalism.


Arendt, Hannah. On Revolution. New York, 1963. Reprint, Westport, Conn., 1982.

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

Dubois, Laurent. A Colony of Citizens: Revolution and Slave Emancipation in the French Caribbean, 1787–1804. Chapel Hill, N.C., 2004.

Heater, Derek. A Brief History of Citizenship. New York, 2004.

Hobsbawm, Eric J. The Age of Revolution: Europe, 1789–1848. London, 1962.

——. Nations and Nationalism since 1780: Programme, Myth, Reality. Cambridge, U.K., 1990.

Holt, Thomas C. The Problem of Freedom: Race, Labor, and Politics in Jamaica and Britain, 1832–1938. Baltimore, Md., 1992.

Marshall, T. H. Citizenship and Social Class, and Other Essays. Cambridge, U.K., 1950.

Nipperdey, Thomas. Germany from Napoleon to Bismarck, 1800–1866. Translated by Daniel Nolan. Princeton, N.J., 1996.

Riesenberg, Peter. Citizenship in the Western Tradition: Plato to Rousseau. Chapel Hill, N.C., 1992.

Scott, Joan Wallach. Only Paradoxes to Offer: French Feminists and the Rights of Man. Cambridge, Mass., 1996.

Sewell, William H., Jr. Work and Revolution in France: The Language of Labor from the Old Regime to 1848. Cambridge, U.K., 1980.

——. The Rhetoric of Bourgeois Revolution: Abbé Sieye's and "What Is the Third Estate?" Durham, N.C., 1994.

Thompson, Dorothy. The Chartists: Popular Politics in the Industrial Revolution. New York, 1984.

Tessie P. Liu


views updated May 29 2018


Citizenship is among the most important concepts in the contemporary world. On the macro level, citizenship is used as a category to allocate the more than 5 billion people on this planet among the various nation-states. On the micro level, citizenship is utilized to describe the attributes of membership in one of those states, and, as a consequence, citizenship frequently becomes an integral part of an individual's personal identity. In short, any discussion of citizenship necessarily entails a discussion of fundamental political relationships.

historical background

Two different elements are involved in the modern concept of citizenship: One is primarily a legal notion, and the other stems from political theory. As one would expect of an idea that has survived transitions from the ancient world of the Greek city-states to the medieval municipalities to the contemporary territorial nation-state, each element in the concept of citizenship contains an extensive network of subordinate components.

In the legal view, the central distinction is between a "citizen" and an "alien." This concept of citizenship stresses the presumed connection between an individual's allegiance to a particular nation and the obligation of that nation's government to protect its citizens. In the political view, the allegiance-protection relationship is only a minimum condition of citizenship. Beginning with Aristotle (384 b.c.e.–322 b.c.e.), political theorists have made a sharp distinction between "citizen" and "subject." Citizens are seen as active participants in the political community; subjects—a category that at various times has included such groups as slaves, serfs, aliens, children, and women—are essentially passive objects of the political community.

The legal element is derived from Roman law. In the ancient Roman Empire, citizenship was originally based not on place or geography, but on the status of the individual within the empire. Thus the New Testament of the Bible records a famous incident in which the Apostle Paul, a Jew from Palestine traveling in what is now Syria, is able to avoid severe prosecution by demonstrating his Roman citizenship (Acts 21: 39; 22: 27–28).

In the Middle Ages, a geographic dimension of citizenship began to emerge in the towns and cities of Western Europe. Those adult men who enjoyed economic advantages and had the exclusive responsibility for the political management of the community were identified as its citizens. Yet the individual or personal dimension was not obliterated. During that same period, the relationship between vassals and feudal lords was discussed in terms of the allegiance a vassal owed his feudal lord for the protection the latter provided. As the nation-state began to emerge out of the medieval world, the duties of feudal allegiance were merged with the duties an individual owed to the government of that territory.

For example, in its fight to maintain its political independence, the England of Elizabeth I (1533–1603) introduced the Oath of Allegiance and Supremacy in 1559, whereby all Englishmen swore their allegiance to the ruler of the realm. Thus the modern legal concept of citizenship, as inherited by the territorial nation-state, represents a combination of these ancient and medieval notions. All citizens of the realm are expected to be loyal to the nation's government, and they are subject to the laws of the land.

The political element also underwent several transformations. In ancient Greece, citizenship was reserved for those men entitled to participate in the governance of their city-state. That notion was carried over to the Roman Republic and, at least symbolically, into the Roman Empire. But after the fall of that empire, the linkage between the ideas of citizenship and participation in governance disappeared for many centuries. The subsequent development of monarchical nationstates saw the continued submergence of the participatory aspect of citizenship. Individuals were discussed and treated as subjects of the Crown. When the American and French revolutions ushered in the modern world in the late eighteenth century, the participatory political element reemerged. Both revolutions asserted the natural rights of humans and the human right of self-government.

fast facts

A person may be a citizen of more than one country.

The American experience illustrates well the transformation of the political concept of citizenship in the modern world. In the English tradition, subjects owed allegiance to the Crown and were reciprocally entitled to the Crown's protection. Early American thinkers transformed subjects into citizens. "'Subject' and 'citizen' are, in a degree, convertible terms as applied to natives," wrote the famous legal authority Chancellor James Kent (1763–1847) in his Commentaries on American Law (1836), "and though the term 'citizen' seems appropriate to republican freemen, yet we are, equally with the inhabitants of all other countries, 'subjects,' for we are equally bound by allegiance and subjection to the government and law of the land" (Kent 1848, vol. 2, p. 258).

American political processes extended the formal rights of citizenship, including political participation, to previously excluded groups. In Kent's time, the franchise was extended to include all white male Americans when the property and tax requirements necessary to vote were removed. In addition, most states introduced the secret ballot to insulate the individual's electoral choice from economic and social reprisals . The addition of the Thirteenth (1865), Fourteenth (1868), and Fifteenth (1870) Amendments to the U.S. Constitution after the U.S. Civil War (1861–1865), extended those same citizenship rights, at least formally, to black male Americans. With the ratification of the Nineteenth Amendment (1920), the right of a citizen to vote could no longer be denied or abridged on account of sex. Native Americans were incorporated into the citizenry by congressional law in 1924. Under the Twenty-Fourth Amendment (1964), a citizen's right to vote could no longer be denied or abridged for the failure to pay a poll or other tax.

With the passage of the 1965 Voting Rights Act, blacks and other racial and ethnic minorities at long last obtained a meaningful (as opposed to a formal) opportunity to participate in political processes in all parts of the country. The Twenty-Sixth Amendment (1971) extended the right to vote to all citizens, otherwise qualified, who had reached eighteen years of age. The concept of equating citizenship with the right (for adults) to participate in governance that had begun in the early nineteenth century was completed.

The American experience of the evolution of citizenship was typical. The rise of the modern nation-state, with its theoretical roots in individual natural rights, required the extension of the franchise to ever-larger groups within a country as a way to demonstrate the government's legitimacy in the age of democracy. Paradoxically, this is best illustrated by the experiences of one-party, nondemocratic states. During Joseph Stalin's (1879–1953) long totalitarian rule of the Soviet Union, for example, elections were frequently held to demonstrate support for the regime , although these elections were controlled by the state. With the collapse of communism and other dictatorships and the corresponding emergence of more democratic regimes, genuinely free elections have become a more general experience. As in the United States, the equation of citizenship with the right to participate politically has meant an ever-increasing number of citizens (defined as eligible voters) and a corresponding decrease—almost to the point of disappearance—of subjects.

In the early 2000s most political scientists identified the "citizenship issue" with the ways in which different societies handle the controversies surrounding the entry into politics—the decision as to when new social groups should obtain access to the franchise. For in this age of democracy, when each person is considered to be a citizen, it is assumed that all individuals ought to have the right to participate politically after reaching adulthood.

continuing significance

At the dawn of the modern era, the legal debate involved discussions about whether citizenship was territorial (and hence at least potentially entailing perpetual allegiance) or personal (and hence at least potentially entailing the voluntary transfer of allegiance). Even after the United States gained independence in 1783, for example, the British maintained that all persons born within their empire owed perpetual allegiance to the Crown; according to this view, residents of the former British colonies had not become citizens of the United States. The British conception provided a justification for them forcibly to impress into their service those American seamen who had been born within the empire. American resistance to this practice was one of the root causes of the War of 1812 (1812–1814). The spread of democracy and the idea of individual human rights destroyed the very thought of perpetual allegiance.

In the contemporary world, citizenship is most usually acquired by birth within the territory of a nation-state. The first sentence of the Fourteenth Amendment to the U.S. Constitution enshrines this notion: "All persons born or naturalized in the United States, and subject to the jurisdiction thereof, are citizens of the United States." (The phrase "subject to the jurisdiction" is meant to exclude generally recognized exceptions, such as children of diplomatic personnel.) The Supreme Court has always given the citizenship clause a literal meaning; consequently, even children born in the United States to legally admitted resident aliens who could not become citizens themselves are entitled to U.S. citizenship. Race, descent, and ethnicity are not related to this territorial conception.

The territorial conception of citizenship still incorporates the idea of allegiance to the nation: An individual is presumed to be loyal to the country of his or her birth. However, because the notion of perpetual allegiance has been rejected, a person is thought to be capable of changing that allegiance by relocating to another country. Within the territorial conception, naturalization is the process whereby an immigrant obtains citizenship by swearing allegiance to the nation of choice.

Not every nation-state, however, utilizes a territorial conception for its legal definition of citizenship. Germany, for example, utilizes a more ethnic membership conception; citizenship adheres to children born to people who are already members of that nation. (The United States also grants citizenship to the children of U.S. citizens when those children are born abroad.) German citizenship is automatically bestowed on individuals born to Germans living abroad, many of whom have never resided in Germany. Many people who were forcibly relocated to Eastern Europe and Russia during the last four centuries of the second millennium have been legally entitled to German citizenship on the basis of their ancestry. To claim German citizenship, they could relocate to German territory and document their German heritage. But Germany has yet to extend citizenship to guest workers—even to thirdgeneration residents of the country.

Some nations utilize a combination of the ethnic and territorial conceptions to legally define their citizenry. Israel, for example, regards itself as the Jewish state, the legal homeland of the Jewish people. Under the Law of Return, an immigrant visa is automatically given to every Jew who expresses a desire to settle in Israel (unless that person poses an imminent health menace or is fleeing justice), and on arrival those Jews are automatically entitled to Israeli citizenship. A non-Jewish individual can obtain Israeli citizenship by a naturalization process similar to that of the United States. Moreover, all people born in Israel's territory are regarded as citizens. Palestinians comprise more than 19 percent of Israel's citizenry and are entitled to all the rights pertaining thereto, including the right to vote for the nation's political leadership.

Citizenship laws define the conditions for an individual's membership in the various nation-states of the contemporary world. In the contemporary world, that membership is the only vehicle through which an individual can claim any human right. The deprivation of citizenship involves the loss of any organized community potentially able to protect a person. Citizenship is the connecting link between an individual and a particular nation.

ongoing issues

The very laws that define the legal criteria for citizenship in a particular nation point to some of the major political problems confronting the nations of the world. Those nations that utilize an ethnic conception to legally define citizenship must confront the issue of how to incorporate individuals from other groups into the body politic. Those nations that utilize a territorial conception to legally define citizenship must confront the issue of how to generate a common national identity in a body politic comprised of multiple ethnic traditions.

Utilizing an ethnic conception is presumed by its proponents to automatically create a strong bond between a nation's government and its people. In the contemporary world, however, very few nations contain only one ethnic group. Most

territories embrace a wide variety of ethnic groups. Twenty-first-century Germany, for example, has almost 1 million ethnic Turks among its 82 million people. Although originally invited into Germany as guest workers, the Turks have established permanent, multigenerational communities, yet they are not permitted to help determine the policies governing the cities and nation in which they reside. This general problem will only become exacerbated by Germany's membership in the European Union. That entity guarantees the free movement of people within the European Union; as a result, many people are immigrating to Germany from other European countries to take advantage of favorable economic conditions. For a nation such as Germany to restrict citizenship to only one ethnic group automatically deprives the others of the basic democratic right of self-government. Furthermore, a legal conception of citizenship that is based on ethnicity may also heighten a parochialism among the majority that could make it more difficult politically to include an ethnic minority.

Germany, of course, is not the only democracy confronting the dilemma created by utilizing a legal definition of citizenship based on ethnicity. The problem arises from the practice of making the enjoyment of rights and privileges conditional on group membership in a world that is dominated by the democratic idea of universal individual human rights. Some countries, such as Israel, have tried to resolve this problem by modifying a primarily ethnic conception with a territorial definition of citizenship for minority groups within the nation. Israel's non-Jewish citizens (primarily Palestinians) are entitled to all the formal, legal rights of citizenship. However, by identifying itself as the Jewish state, Israel is functionally an "ethnic democracy"—Jews and Palestinians formally enjoy equal citizenship rights, yet only Jews determine the nation's basic policies. By considering itself to be the political expression of the Jewish people, who are not defined as the people residing in a particular geographic territory, it is impossible for a non-Jewish citizen to have that sense of membership in the larger society that is integral to the political theory conception of citizenship.

The political theory conception of citizenship illuminates the plight of minorities in many nations, even those that legally define citizens in territorial terms. In India, the world's largest democracy, Muslims and Sikhs have great difficulty believing that they enjoy citizenship rights equal to Hindus. The two minority groups recognize that religiously-based parties among the Hindu majority limit their political rights. Realistically, their aspirations have been limited to achieving formal legal recognition of their human rights and economic equality. In terms of the political theory conception of citizenship, full and equal participation in the governance of India by its minority groups is only a distant dream.

Similarly, the concept of citizenship highlights fundamental problems present in other democracies. As previously noted, the United States utilizes the legal definition of citizenry to emphasize the individualistic basis of membership in American society. To create a common sense of national identity, Americans have utilized an ideological element: attachment to the basic principles of the constitution. An understanding of American citizenship is based on the belief that the right kind of individual would be welcome, regardless of background. The individual not fortunate enough to become attached to American constitutional principles based on birth could still develop the habits of mind and action to be a "real" American.

E pluribus unum (meaning "out of many, one") is the motto on the Great Seal of the United States. The need to fuse individuals who trace their ancestry to every other country in the world into one nation—a unified people with shared beliefs and values—is a continuing theme in American politics. The basic problem has always been how to make sure that each new group of immigrants discovers a shared attachment to the basic principles of the constitution.

Because the principles of the U.S. Constitution are broad, general statements, it is notoriously easy to claim that a particular group's traditions make its members inherently unable to accept basic American values. The specific target groups have varied over time, but the basic accusations have remained constant. Such nativist (i.e., favoring natives over immigrants) politics have frequently been harmful, posing a threat both to the target groups and to national stability. Yet when cooler heads have prevailed and a sense of calm has returned, previously attacked groups have been seen as true Americans. The individualistic cast of American citizenship has meant the absence of any permanent barriers to one particular group coming to be accepted within the American fold. The slow, concomitant acceptance of the pluralistic culture that has developed in the United States makes full, equal citizenship a feasible objective.

See also: Immigration and Immigrants; Naturalization.


Jacobsohn, Gary Jeffrey, and Susan Dunn, eds. Diversity and Citizenship. Lanham, MD: Rowan & Littlefield, 1996.

Kent, James. Commentaries on American Law, 6th ed., 4 vols. New York: W. Kent, 1848.

Kymlicka, Will. Multicultural Citizenship. New York: Oxford University Press, 1995.

Pranger, Robert. The Eclipse of Citizenship. New York: Holt, Rinehart and Winston, 1968.

Riesenberg, Peter. Citizenship in the Western Tradition. Chapel Hill: University of North Carolina Press, 1992.

Spinner, Jeff. The Boundaries of Citizenship. Baltimore, MD: Johns Hopkins University Press, 1994.

Martin Edelman


views updated May 23 2018


Citizenship meant much to firstgeneration Americans who had consciously cast off their identities as subjects of the British monarch and declared themselves members of a republic. This would, however, intersect with traditional notions of status that defined privileges and duties locally and hierarchically. Citizenship, with its suggestion of a national, egalitarian identity was thus a concept central to the Revolutionary enterprise yet often subjugated in the early Republic to local determinations of status that doled out privileges and duties unequally.

subjectship in the british empire

American colonists at the close of the Seven Years' War (1756–1763) thought of themselves as subjects of the British monarch. The legal doctrine of subjectship had been articulated over a century earlier by English jurists. Only subjects of the king could own property and bring suits in the king's courts. Aliens may have owed temporarily allegiance by their residence in England, but they lacked the privileges of subjects unless Parliament naturalized them. All those born in the realm of England were natural-born subjects, immediately enjoying the protection of the monarch and owing allegiance in kind. This doctrine of allegiance was a reflection of divinely ordained hierarchies, similar to the filial bond of a child to a parent, and was as such natural and perpetual. Although allegiance involved reciprocal rights and duties, it was not a contractual bond. Neither subject nor monarch nor both together could, of his or her own volition, cast off the bond.

John Locke challenged this notion in his Two Treatises on Civil Government (1690). Rather than hierarchical inequality enshrined in feudal bonds of allegiance, Locke argued that the bond between governors and governed stemmed from man's perfect freedom in the state of nature and was thus a consensual bond. This implied that governors were limited in their power, which left to the governed the absolute rights to life, liberty, and property that they had not consented to turn over to the government. Independent of Locke's natural rights were the political rights of freeborn Englishmen, which included the right to petition the king with grievances, to hold free elections, to have recourse to the writ of habeas corpus, to receive a trial by jury, and to consent to taxation, along with a host of other privileges. These rights were repeatedly asserted during the seventeenth century and became a centerpiece of the constitutional settlement of the Glorious Revolution of 1688 in the English Bill of Rights.

Elements of both these theories worked their way into British law. William Blackstone separated the reciprocal rights and duties of subjects and monarch from the absolute rights of people in his Commentaries on the Laws of England (1765–1769). Absolute rights, however, did not govern the law of persons. More important in determining someone's status was the common law relations of husband and wife, master and servant, parent and child. Corresponding duties of protection and obedience marked each of these relationships, enforcing a patriarchic legal regime.

the american revolution

During the 1750s and 1760s, the question of subjectship in the British Empire arose. Notions of the rights of freeborn Englishmen collided with the ascendancy of the doctrine of parliamentary sovereignty and the reality of administering an empire, particularly during war with France. To deal with a rebellion in the Scottish Highlands, the British Parliament in the Militia Act of 1757 deprived all Scots of the right to raise and regulate a militia. The Stamp Act of 1765 established an internal tax on the colonists to which they had not directly consented. The Massachusetts Government Act—part of the Intolerable Acts of 1774—annulled its charter and put the colony under military rule. While these actions of Parliament engaged a number of complicated constitutional issues, they impacted broadly the question of what kinds of privileges and immunities were enjoyed by British subjects outside the realm of England.

The thirteen colonies responded in 1776 to the imperial crisis by withdrawing their allegiance and drawing up independent constitutions. This had the revolutionary effect of changing subjects into citizens by transforming allegiance from an incident of feudal relations to an expressly consensual bond. This doctrine of consent suffered practical difficulties with the large number of British Loyalists resident in every state who did not elect to join the new polity in wartime. The states responded by treating Loyalists as citizens or as conquered subjects. Eventually, however, every state adopted a legal doctrine of elective membership in the polity.

naturalization laws

The U.S. Constitution made almost no mention of citizenship other than to guarantee that the "Citizens of each State shall be entitled to all Privileges and Immunities of Citizens in the several States" (Article IV, section 2) and to require a uniform rule of naturalization. The First Congress moved quickly to provide this rule, passing a naturalization act in 1790 that set a minimal residency requirement of two years. Congress raised this to five years in 1795 and limited jurisdiction over naturalization to U.S. district and territorial courts. Heightened anxiety during the Quasi-War with France (1798–1800) prompted the Federalist Congress to pass a new naturalization act in 1798 that raised the waiting period to fourteen years.

In 1802 the Democratic Republican–controlled Congress repealed the 1798 act and restored both the five-year residency requirement and the jurisdiction of any common law court, state or federal, over the naturalization process. This was, however, a Democratic Republican triumph over Federalist centralization rather than a commitment to freer immigration and naturalization. It was the states, not the national government, that placed restrictions on immigrants crossing their borders. In 1787 Georgia prohibited the immigration of any convicted criminal from either a foreign country or another state, and many states passed similar laws. After 1820, Massachusetts required shipmasters to provide security for passengers that might become paupers, and most states passed quarantine or registration laws that allowed them to refuse entry to foreigners deemed undesirable.

U.S. law stipulated in every case that naturalization was open only to "any alien being a free white person," a condition that eliminated Native Americans from consideration. While many agreed that Native Americans did not qualify as citizens of the new Republic, no single reason was cited. Some considered Native Americans' tribal allegiance as a barrier while others argued that Indians would forever be dependent on the superior intelligence of white men for their protection. Still, several treaties with Native Americans contemplated the possibility of future Indian citizenship. None of these treaties, however, achieved this goal.

Federal courts and officers generally concurred that Native Americans could not be naturalized under normal circumstances. Chief Justice John Marshall declared in Cherokee Nation v. Georgia (1831) that Indian tribes were not foreign states in the sense meant by the Constitution. Instead, they were "domestic dependent nations," an ambiguous term suggesting that tribes were like wards and that the United States was their guardian.

republican citizenship

The naturalization debate of the 1790s triggered anxieties about the nature of republican citizenship. Many congressmen argued that America needed to encourage immigration but some worried that an influx of European immigrants would undermine republican simplicity. James Madison argued as early as 1790 that it was not immigration that Congress needed to encourage, but attachment to the Republic. While everyone agreed with Madison in principle, there was little agreement about how to accomplish it.

The stakes were high. Republics rose and fell, Americans believed, based on the interplay between virtue and corruption. America's ability to survive would depend on the general intelligence, public virtue, and moral worth of its citizens. Religion, the traditional guardian of public morality, was fractured into many different churches. The push by dissenters for disestablishment further complicated the ability of religious institutions to communicate a common message.

To correct this, republicans stressed education as the means of securing the proper values in citizens. Noah Webster (1758–1843), Benjamin Rush (1745–1813), and Thomas Jefferson (1743–1826) all worked to establish elementary and higher education that would not only train people in the practical arts, but also prepare young people for the duties of civic membership in a republic. Education also promised a kind of equality based on independence and mobility. Educated citizens had the ability to improve themselves and this would, as Thomas Jefferson stressed, contribute to an equality of opportunity.

Women played a crucial role in education. Motherhood took on new meaning when it became infused with the duty of instilling the republican values of public virtue, integrity, and self-reliance—traits that women were now prompted to exhibit by example rather than just passively teach. This grafting of liberal civic duty onto traditional roles had revolutionary potential. Although they were duties exercised in the private home, they gave women new duties of citizenship. Still, women's status as citizens in the early Republic was unclear. Hampered by coverture, the legal doctrine that a woman's status was "covered" by her husband, married women had no independent legal identity and thus could not own property or bring suit in a court of law. In addition, most states barred women from officeholding, jury service, and voting regardless of their marital status.

While republic citizenship did redefine roles for men and women in the polity, loyalties throughout the Republic remained primarily local. Because the law defined people's rights and duties in terms of their membership in village, town, and state, United States' citizenship did not carry with it a host of privileges guaranteed by national law. Congressmen made clear during the naturalization debate that the Constitution's call for a uniform rule of naturalization did not grant uniform privileges. States separated civil protections, property holding, and suffrage and distributed these privileges to their residents at their own discretion.

democratic expansion and restriction

Despite the absence of a national policy, patterns in the course of citizenship emerged during the early Republic. One was the democratic expansion of suffrage. Jefferson's optimism about the abilities of the common man challenged classical republicanism's insistence that only the propertied and wealthy exhibited the independence necessary to direct affairs of state. Classical republicans held that wage earners, artisans, and servants would be dependent upon their employers and easily corrupted or controlled. Hence, every state at the time of the Constitution's signing had some kind of property qualification for suffrage.

The Democratic Republican victory in the election of 1800 signaled the end of this regime. With Jefferson's support, Democratic Republicans in the states worked to repeal property requirements for suffrage. Maryland passed a universal white male suffrage bill in 1801 and other southern states quickly followed suit. After the admission to the Union in 1820 of Maine, with its constitution guaranteeing universal white male suffrage, Massachusetts and New York dropped their property qualifications. By 1829 only Virginia, South Carolina, Louisiana, Connecticut, and Rhode Island had not adopted universal white male suffrage.

Despite these liberal tendencies, the legal regime of the early Republic retained the status distinctions inherent in the common law. This meant that one's relative privileges, immunities, and duties flowed from the law of persons. In addition, states retained through their police power wide discretionary authority over their inhabitants, including the ability to adjudge status and apply relative rights and duties. For instance, many states passed vagrancy laws after the Revolution that allowed justices of the peace and town overseers summarily to commit people deemed common vagrants, drunkards, and prostitutes to workhouses without benefit of a formal judicial hearing. In these cases, local status trumped any notion of universal citizenship.

Liberal democratic expansion had its own limits as well. Women found any voting rights that they possessed extinguished by universal manhood suffrage, as when New Jersey took away the right of propertied, single women to vote in 1807. Most southern states had forbidden free blacks from voting and performing civic duties such as serving on juries. Those states that granted privileges to free blacks revoked many of them after 1800, as Maryland did when it disenfranchised free blacks in 1810. Tennessee and North Carolina would restrict their generous provisions for free blacks in 1834 and 1835, respectively. Conditions in the North were little better. Outside New England, most northern states denied free blacks the suffrage. New York's revised constitution of 1826 both eliminated property qualifications for whites and increased them for blacks. As a result, only sixteen African Americans of a free black population of nearly thirteen thousand qualified to vote.

African Americans, enslaved and free, faced other impediments. In the North, free blacks not only found their commercial and political rights diminished, but also had their access to education restricted. Most northern and western states segregated schools by law or custom, and many appropriated no money for black schools. Conditions in the South were worse. Missouri's state constitution of 1820 forbade the immigration of free blacks. North Carolina required free blacks to wear a patch reading "FREE" on one shoulder and also to register with authorities, a policy adopted by other southern states. Free blacks throughout the South were required to carry proof of their status; blacks without papers were presumed fugitives from slavery. Some states denied blacks any kind of citizenship out of hand. Georgia's superior court declared in Ex parte George (1806) that "free negroes, persons of colour, and slaves, can derive no benefit from [Georgia's] constitution." James Monroe's attorney general, William Wirt, concluded in an 1821 opinion that free blacks could not be citizens because no person could be considered "in the description of citizen of the United States who has not the full rights of a citizen in the State of his residence." Wirt's logic implied that neither women nor minors were citizens, although he did not intend to draw this conclusion. What his position revealed was not so much doctrinal inconsistency, but rather that a variety of statuses existed at the state level and that they, rather than appeals to universal citizenship, determined membership, rights, and duties.

See alsoAfrican Americans: Free Blacks in the North; African Americans: Free Blacks in the South; Alien and Sedition Acts; Education: Overview; Immigration and Immigrants: Immigration Policy and Law; Law; Politics: Political Thought; Voting; Women: Rights .


Berlin, Ira. Slaves without Masters: The Free Negro in the Antebellum South. New York: Pantheon Books, 1974.

Horton, James Oliver, and Lois E. Horton. In Hope of Liberty: Culture, Community, and Protest among Northern Free Blacks, 1700–1860. New York: Oxford University Press, 1997.

Kerber, Linda. No Constitutional Right to Be Ladies: Women and the Obligations of Citizenship. New York: Hill and Wang, 1998.

Kettner, James H. The Development of American Citizenship, 1608–1870. Chapel Hill: University of North Carolina Press, 1978.

Neuman, Gerald L. Strangers to the Constitution: Immigrants, Borders, and Fundamental Law. Princeton, N.J.: Princeton University Press, 1996.

Novak, William J. "The Legal Transformation of Citizenship in Nineteenth-Century America." In The Democratic Experiment: New Directions in American Political History. Edited by Meg Jacobs, William J. Novak, and Julian E. Zelizer. Princeton, N.J.: Princeton University Press, 2003.

Shklar, Judith N. American Citizenship: The Quest for Inclusion. Cambridge, Mass.: Harvard University Press, 1991.

Smith, Rogers M. Civic Ideals: Conflicting Visions of Citizenship in U.S. History. New Haven, Conn.: Yale University Press, 1997.

H. Robert Baker


views updated Jun 08 2018



Citizenship can be succinctly defined in terms of two component features. First, it constitutes membership in a polity, and as such it inevitably involves a tension between inclusion and exclusion, between those deemed eligible for citizenship and those who are denied the right to become members. In its earliest form in ancient Greece, the polity in question was the city-state. In the modern world, it was transformed during the era of democratic revolutions into the nation-state. Second, membership brings with it a reciprocal set of duties and rights, both of which vary by place and time, though some are universal. Thus paying taxes and obeying the law are among the duties expected of citizens in all nations, while the right to participate in the political process in various waysby voting, running for office, debating, petitioning, and so forthis an inherent feature of democratic citizenship. This leads to a final point: citizenship exists only in democratic regimes, for in nondemocratic ones people are subjects rather than citizens. In this regard, there are three crucial features that characterize the democratic political system: (1) the right to participate in the public sphere; (2) limitations on the power of government over the individual; and (3) a system based on the rule of law, not the arbitrary rule of rulers.

The principal fault lines used to define the boundaries of inclusion versus exclusion have historically been based on three major social divisions: class, gender, and race. And, indeed, though much has changed, these divisions remain significantand in fact tend to be intersecting. During the formative period of all the modern democratic regimes, beginning in the eighteenth century, the privileged white, property-owning male citizens were intent on disqualifying a majority of their nations residents from citizenship rights. Confronted with a disjunction between the egalitarian ideals of democratic theory and the desire to exclude from full societal membership certain categories of persons who did not share their class, gender, or racial identities, they responded by creating justifications for social exclusion. For their part, the white working class, women, and nonwhites responded, always in difficult circumstances and with varying degrees of success, by creating social movements aimed at acquiring the political voice that had been denied them. The white working class had, by the late nineteenth century, succeeded in being included, though not as genuine equals. A similar inclusion would come slower for women and racial and ethnic minorities, where in many cases this did not occur until the later part of the twentieth century. Thus, American blacks did not overcome the barriers created by Jim Crow until the 1960s, Australias Aboriginal population did not receive the right to vote until the same time, and in some Swiss cantons women did not acquire the right to vote until 1990.

As with inclusion, the development of the rights of citizens entails a dynamic process. Analyses of this process are generally framed in terms of the thesis advanced by the British social theorist T. H. Marshall, who distinguished between three types of rights: civil, political, and social. In his view, these types are distinct not only analytically, but also historically. Civil rights refer to such aspects of individual freedom as free speech, freedom of religious expression, and the right to engage in economic and civic life. Political rights involve those rights that ensure the ability to actively participate in the realm of politics. Finally, social rights involve the rights to various welfare provisions designed to guarantee to all a minimum standard of living necessary for the other two rights to be meaningful. Included are guarantees of educational opportunities, health care, decent and affordable housing, pensions, and so forth. Marshall thought that civil rights emerged in the eighteenth century, political rights in the nineteenth, and social rights in the twentieth, with the birth of modern welfare states. The historical record calls into question the unilateral depiction of the evolution of rights, but it is the case that all of the worlds liberal democracies did develop welfare states guaranteeing various forms of social rights. In his view, whereas the other types of rights do not challenge capitalisms production of unacceptable levels of inequality, social rights are intended to do so. Inequality does not cease to exist, but it becomes less consequential in shaping the life chances of individuals and impeding the goal of the equality of people qua citizens. The historical record indicates that welfare states have not actually managed to achieve this goal, and moreover, the neoliberal assault on the welfare state has resulted in an increase in levels of inequality.

Debates over the duties of citizens have pitted republican (and communitarian) theory versus liberal theory. The former position calls for an involved citizenry, while the latter is less inclined to ask or require citizens to be too actively engaged in politics. For example, republicans would be inclined to support universal conscription into military service or some alternative form of public service while liberals would not. Nevertheless, both positions believe that for democracies to succeed they need an informed and active citizenry. The distinction between the two traditions has much to do with differing perspectives on the levels of activity required. By the latter part of the twentieth century, a lively discourse emerged about the presumed tendency on the part of citizens in the United States, and to a somewhat lesser degree elsewhere, to withdraw from civic and political involvement, as evidenced, for instance, in the widespread interest in the Harvard political scientist Robert Putnams bowling alone thesis.

If in the past citizenship has been construed in terms of the individual, multiculturalism has raised the specter of the emergence of group rights. Although many, but not all, of the worlds liberal democracies have developed a multicultural sensibility, only two to date have implemented official state policies designed to promote multi-culturalism: Canada and Australia. While some observers contend that the multicultural moment has ended, they fail to appreciate its novelty, specifically, as the scholar Jeffrey Alexander has argued, insofar as it signals a new form of civil society. Moreover, even without explicit multicultural agendas, there is evidence of a growing appreciation that difference and integration are not necessarily antithetical.

Finally, there is evidence of a growing interest in developments that suggest the world is entering a new era in which the nation-states monopoly on defining citizenship is being challenged. In part, this is due to the rapid expansion of people with dual or multiple citizenships and the growing willingness by governments to legalize or tolerate this situation. This increase is largely attributable to transnational immigration, which though not entirely new is more significant today due to new communications technologies and improved transportation networks. Whether or not transnationalism is largely a phenomenon of the immigrant generation, or will persist into the generations of their children and grandchildren, is an unanswered question in the early twenty-first century. Likewise, it is also unclear whether dual citizenship becomes merely formal, in which the citizenship of primary residence is the only salient one, or whether active involvements in two nations political systems persist.

Second, as exponents of postnationalist thought contend, supra-state entities such as the United Nations and the European Union (EU) are increasingly coming to assume some of the roles traditionally located solely with the nation-state. This is particularly the case with the issue of human rights, where there is evidence of the embryonic form of a global human rights regime. It is also relevant to environmental concerns, as the Kyoto Protocol makes clear, for these are matters that transcend existing political borders. Although the EU is unique, the fact that citizens of its member states can treat their social rights as applying outside of their national boundaries signals yet a new development of interest. In such a situation, social rights are portable within the EU, thus for example allowing German retirees to move to Portugal while collecting their German pensions, while at the same time permitting Portuguese workers free access to German labor markets. Much remains uncertain about where these developments might lead, but given the pace of change since the mid-twentieth century many social scientists predict that the twenty-first century will see changes in the location of citizenship brought about by globalization. At the same time, some of the earlier enthusiasm about the prospects for the decline of the nation-state has been unrealized, and in fact in the so-called age of terrorism nation-states have reasserted themselves and in the process raised concerns about the erosion of some rights.

SEE ALSO Civil Rights; Civil Society; Immigrants to North America


Alexander, Jeffrey C. 2006. The Civil Sphere. New York: Oxford University Press.

Kivisto, Peter. 2002. Multiculturalism in a Global Society. Malden, MA: Blackwell Publishing.

Kivisto, Peter, and Thomas Faist. 2007. Citizenship: Discourse, Theory, and Transnational Prospects. Malden, MA: Blackwell Publishing.

Marshall, T. H. 1964. Class, Citizenship, and Social Development. Garden City, NY: Doubleday and Company.

Putnam, Robert. 2000. Bowling Alone: The Collapse and Revival of American Community. New York: Simon & Schuster.

Turner, Bryan S. 1986. Citizenship and Capitalism. London: Allen & Unwin.

Peter Kivisto

Citizenship: Naturalization

views updated Jun 11 2018

Citizenship: Naturalization

Citizenship rests with territory at the heart of the definition of nation-state. If territory determines the geographical limits of state sovereignty, citizenship determines a state's population. Beyond these limits one finds foreign land, foreign sovereignty, and foreigners. Drawing the boundary within which some human beings are included and others excluded as foreigners, permitting some of them to acquire citizenship with certain conditions and others to lose citizenship, is a state prerogative that requires legal tools. In citizenship law, the two most important legal tools traditionally used to determine citizenship are:

  1. Birthplace, or jus soli, the fact of being born in a territory over which the state maintains, has maintained, or wishes to extend its sovereignty.
  2. Bloodline, or jus sanguinis, citizenship as a result of the nationality of one parent or of other, more distant ancestors.

All nations use jus soli and jus sanguinis in defining attribution of citizenship at birth. However, two other tools are used in citizenship law, attributing citizenship after birth through naturalization:

  1. Marital status, in that marriage to a citizen of another country can lead to the acquisition of the spouse's citizenship.
  2. Past, present, or future residence within the country's past, present, future, or intended borders (including colonial borders).

In eighteenth-century Europe, jus soli was the dominant criterion of nationality in the two most powerful kingdoms: France and the United Kingdom. The state simply inherited feudal tradition: human beings were linked to the lord who held the land where they were born. The French Revolution broke with this feudal tradition. Against Napoléon Bonaparte's wish, the new civil code of 1804 granted French nationality at birth only to a child born to a French father, either in France or abroad. This policy of jus sanguinis, representing a modern innovation, was not ethnically motivated; it simply reflected the fact that individual rights and family had become more important than subjecthood and state power. This French innovation was borrowed extensively and became the law in Austria (1811), Belgium (1831), Spain (1837), Prussia (1842), Russia (1864), Italy (1865), Netherlands (1888), Norway (1892), and Sweden (1894).

The British tradition of jus soli, on the contrary, was transplanted, unamended and unbroken, to Britain's colonies in North America (the United States and Canada), Europe (Ireland), Africa (South Africa), and Australia. It also influenced Portugal and Denmark until the Nordic countries adopted a common nationality regime in the 1920s.

Were a population and territory to match one another exactly, attributing citizenship on the basis of jus sanguinis, jus soli or residence would not make any difference. Citizenship law would concern the same population and would have the same juridical effects. Further, naturalization would be irrelevant. It is the case, of course, that the population and territory of a nation-state do not coincide. People migrate and, with respect to migration, one can distinguish broadly between two different types of countries:

  1. "Countries of emigration" are countries where part of the core population resides outside the national boundaries, a characteristic applying to the majority of European countries before World War II (with the exception of France), and Mexico since the 1930s.
  2. "Countries of immigration" are those in which the majority of citizens are immigrants or descendents of immigrants, or whose foreign populations have settled as permanent residents alongside a majority population that is perceived to have existed since time immemorial and is not descended from immigrants. The United States, Canada, and Australia and countries of South America are examples of the former, while the latter category includes France since the mid-nineteenth century and all other western European countries since World War II.

The legal traditions of jus soli and jus sanguinis were maintained with consistency and relative ease in the majority of these different countries until World War II. In countries of immigration such as the United States, jus soli allows the children of immigrants to acquire citizenship automatically. For continental European countries that were countries of emigration, jus sanguinis allowed citizens abroad to maintain links until their descendants lost touch.

Since World War II, however, citizenship laws have converged across all democratic states, due to the large increase in the scale of migrations across the world. In many continental European states, large-scale postwar immigration led to legislative changes so as to permit increasingly large segments of the population born in their territories, namely second-and third-generation immigrants, to access citizenship more easily. Elements of jus soli have been included in their jus sanguinis tradition that extends citizenship automatically at birth to third-generation immigrants (France since 1889, the Netherlands since 1953, Spain since 1990, and Belgium since 1992). For the second generation, in many countries, children born to immigrants on national territory are entitled to citizenship if the child (Belgium, Denmark, Finland, France, Italy, Netherlands, Spain, Sweden) or one of the child's parents (Germany) has lawfully resided there for a period of years.

Countries with nationality laws based upon automatic jus soli often attracted a number of immigrants into their territory, encouraging these countries to become more restrictive. For example, the United Kingdom's imperial and expansive conception of territory, combined with its jus soli tradition, involuntarily encouraged immigration. Just after World War II, all subjects of the British Empire had access to British citizenship simply by residing in the territory of the United Kingdom proper. Since that time, British legislation on nationality has undergone a swift and silent revolution away from the extended and automatic jus soli to a 1981 law that attributes citizenship only to children born in U.K. territory to parents with legal residence status. The legal residence of parents has also been included as a requirement in the Portuguese and South African laws.

The trend toward convergence in nationality laws concerns almost all advanced industrial countries, insofar as they share three basic characteristics: democratic values, stable borders, and a self-perception as countries of immigration rather than of emigration. The importance of these three conditions is confirmed when considering exceptions to this rule, such as Israel and Russia. In both countries, there is a dominant perception that many of their citizens reside outside their borders, and that the bordersindispensable for the definition of the soliare not stable. Jus sanguinis thus remains at the center of both of their citizenship laws. But for all countries, regardless of their situation concerning migration or their level of development, there are two distinct lines of convergence in nationality laws. First, there has been a notable trend since the mid-twentieth century toward repealing provisions for the automatic acquisition of citizenship through marriage, a move motivated at the same time by the development of equal rights between men and women in nationality laws and by worries about fraudulent marriages with illegal aliens. Second, equal rights between men and women to transmit their citizenship to their children has produced the development of dual citizenship and more toleration of this phenomenon in many countries that formerly refused it (for example, Switzerland since 1990). What remains divergent are the rules for naturalization; that is, the processes by which foreign residents of the first generation access citizenship in a host country. States generally require a period of residence and knowledge of the language, and take into account a criminal record, but the details of these requirements still vary greatly, both in the formal requirements of nationality laws and in the practices through which these laws are enforced.

See also Americanization, U.S. ; Citizenship: Cultural Citizenship .


Aleinikoff, T. Alexander, and Douglas Klusmeyer. Citizenship Policies for an Age of Migration. Washington, D.C.: Carnegie Endowment for International Peace, 2002.

Aleinikoff, T. Alexander, and Douglas Klusmeyer, eds. Citizenship Today: Global Perspectives and Practices. Washington, D.C.: Carnegie Endowment for International Peace, 2001.

Hansen, Randall, and Patrick Weil, eds. Dual Nationality, Social Rights, and Federal Citizenship in the U.S. and Europe: The Reinvention of Citizenship. New York: Berghan, 2002.

. Towards a European Nationality: Citizenship, Immigration and Nationality Law in the EU. Houndsmills, U.K., and New York: Palgrave, 2001.

Weil, Patrick. Qu'est ce qu'un français? Histoire de la nationalité française depuis la Révolution. Paris: Grasset, 2002.

Patrick Weil


views updated May 08 2018


CITIZENSHIP. The concept of citizenship was at the heart of the Constitution. When Thomas Jefferson wrote in the Declaration of Independence in 1776, "We hold these truths to be self-evident, that all men are created equal, that they are endowed by their Creator with certain unalienable rights, that among these are life, liberty and the pursuit of happiness. That to secure these rights, governments are instituted among men, deriving their just powers from the consent of the governed," he drew upon the writings of the ancient Greeks Solon (circa 640–559 b.c.) and Pericles (490–429 b.c.) who had argued that the state has legitimacy only so far as it governs in the best interest of its citizens.

Jefferson argued that citizens were autonomous beings whose individual needs had value, and he said that governments that interfered with the fulfillment of those needs—"life, liberty and the pursuit of happiness"—were tyrannical and unjust. By "all men," he meant every human being. That Jefferson continued to own slaves shows a profound weakness in his character, but men and women of many ethnic backgrounds understood his words to apply to them, and the ideals of Jefferson were the intellectual foundation upon which many revolutions would follow.

In America, those ideals encouraged abolitionists and suffragettes. When the Constitution was written, its authors were well aware of the ideals that had motivated Americans to fight for their freedom from England. They carefully began the Constitution with a radical, defiant idea. "We the People" is the opening phrase, and it is presented as if it were a decree. In a monarchical society, the monarch would refer to himself or herself as "we," because he or she believed as Louis XIV put it, "I am the state." In a monarchy, power flows down from the top: a person's power stems from his or her relationship to the monarch, and a person has only as many rights and duties as the monarch should choose to give. In "We the People," this is reversed; the power of the new American government is to flow upward, not downward, and the powers of those who govern are to be only as great as the citizens should choose to give.

What constitutes a citizen became a matter of urgent debate because equality and freedom were tied to citizen-ship. Article I of the Constitution made three references to citizenship, in Sections 2, 3, and 8 (clause 4), governing the House of Representatives, the Senate, and naturalization. Representatives had to have been citizens for seven years and senators for nine years; the U.S. Congress had the power to set the rules for naturalizing citizens. Missing is a definition of citizen, an important point because the representatives in the House were to be apportioned throughout the United States primarily on the basis of population. It was understood that this included free women and children, but did it include slaves? If it did, would the slaves therefore be citizens entitled to the liberties of the Constitution? For the time being, the slaves were not to be counted.

Article II, Section 1 of the Constitution declared that to be president (and therefore vice president, too), a "person" must be "a natural-born citizen" and must have "been fourteen years a resident within the United States." The purpose of this was to make illegal the imposing of a foreign ruler on the nation, but it left in doubt what "natural-born" meant, although it customarily was interpreted to mean born within the borders of the United States or born within the borders of the colonies that became the United States.

It was Article IV that would form the basis of the lawsuit Dred Scott v. Sandford that resulted in the infamous Supreme Court ruling of 1857. In Section 2, the constitution declares "the citizens of each State shall be entitled to all privileges and immunities of citizens in the several States." Yet, the matter of who was a citizen was left to the individual state. Thomas Jefferson argued in the vein of Solon that only by being able to vote in the election of leaders is a person truly a citizen, and he argued that being able to vote was both a right and an obligation for every free person; he believed everyone who met the minimum age requirement should be able to vote. John Adams disagreed; he argued that only people who owned property had enough interest in maintaining a just and stable government and that only they should be allowed to vote. This latter idea implied two tiers of citizenship: one with all the rights and responsibilities of citizenship and one with only limited rights and responsibilities that could change by a person's purchasing land. When the Bill of Rights was passed, it was intended to apply to all citizens, landed or not, but many understood the Bill of Rights applied only to property-owning citizens and no others, even foreign nationals who had resided in the United States for many years.

The Matters of Slaves and Women's Citizenship

Jefferson's view slowly supplanted Adams's view, but out of the Constitution emerged at least two explosive disagreements over who merited citizenship. One was over the status of women; the other was over the status of African Americans. After the adoption of the Constitution, there was an erosion of the civil rights of women throughout the country. In those states where women had once been able to hold public office or even vote, women were denied access to polling places. In general, women were held to have rights only through their relationship to husbands or close male kin. This sparked a branching in the abolitionist movement, as women abolitionists tied liberty for slaves to civil rights for women.

In 1857, the Supreme Court heard the appeal of the case of the slave Dred Scott, a slave who had filed suit claiming that when his master took him to a free state while in that state he should be a free man because that state forbade slavery. The court ruled that "negroes of the African race" whose ancestors were "imported into this country, and sold and held as slaves" were not "people" as the word was used in the Constitution, and they could not have citizenship and therefore they did not have even the right to file a lawsuit in the first place. This ruling actually contradicted the idea of "states' rights" as it was understood at the time, but the decision was a political one, not a constitutional one, and was intended to avoid the potential for civil strife between free states and slave states.

President Abraham Lincoln brought to office a view of citizenship born out of his upbringing on the frontier. He saw citizenship as a means for even the poorest Americans to seek redress of wrongs and to have access to education and other sources of social mobility. He summarized this in his Gettysburg Address, in which he said the government of the United States was "of the people, by the people, and for the people." It was his view that the government had no legitimacy beyond what the people gave it, yet in "for the people" he meant that the government was obliged to actively help its people in attaining their civil rights.

His supporters in Congress were called the "Radical Republicans" because they wanted to reshape America's institutions to reflect fully the sovereignty of the individual human being; to them "people" applied to every human being. Thus they sought the abolition of slavery, and most hoped to follow the emancipation of all slaves with the full enfranchisement of women because only by receiving the full protection of the Constitution, including the vote, could women attain a government that represented them; otherwise, according to Lincoln, Jefferson, and even Solon, the government would be tyranny. The Democrats, who had opposed the freeing of slaves, bitterly opposed changing the constitutional status of women.

The Fourteenth Amendment

The Fourteenth Amendment was intended to clarify the nature of American citizenship. For instance, it tried to explain what a "natural-born citizen" was and how to determine it. Its broadest and most important innovation was the assertion of the federal government's authority over every state in all matters pertaining to citizenship. It declared that any citizen of the United States was automatically a citizen in any state in which that person resided, even if that person moved from state to state. It declared that in counting people for representation in the House of Representatives, every human being was to be included except for "Indians not taxed," which meant those Native Americans who retained their native nationality rather than assimilating into American society.

Best known from the amendment is "No State shall make or enforce any law which shall abridge the privileges or immunities of citizens of the United States; nor shall any State deprive any person of life, liberty, or property, without due process of law; nor deny to any person within its jurisdiction the equal protection of the laws." The amendment was ratified 9 July 1868. Hundreds, perhaps thousands, of lawsuits have been filed on the basis of the amendment, but court rulings have had a checkered history. Although the amendment uses the word "person" throughout, women were still denied the right to vote and were denied full protection under the law in business and family dealings. When the issue of segregating African Americans from other Americans first came before the Supreme Court, it ruled that "separate but equal" was not a violation of equal protection under the law.

The Nineteenth Amendment of the Constitution says, "The right of citizens of the United States to vote shall not be denied or abridged by the United States or by any State on account of sex." This was ratified 18 August 1920. If, in light of the Fourteenth Amendment, women were in fact already citizens, this amendment would seem unnecessary, but the earlier amendment had been turned on its head, as if it meant that those states in which women had full citizenship rights did not have the federal rights unless the federal government said so. With the ratification of the Nineteenth Amendment, women, by being able to vote, were to take on the full obligations and rights of citizenship and were no longer to be regarded as half persons, half nonentities.

Some Twentieth-Century Consequences

In 1954, the full effect of the Fourteenth Amendment began to be realized. In the case of Brown v. the Board of Education, the Supreme court ruled that separation of people based on race was inherently unequal, a violation of the Fourteenth Amendment. This began a series of rulings in federal courts that redefined citizenship as a human right not to be abrogated by government, resulting in the 1971 ruling in Rogers v. Bellei that declared the government could not take citizenship from any American citizen except as allowed by the Fourteenth Amendment (treason) or if the citizen were a naturalized citizen who had lied to gain entry to the United States or gain citizenship. Those people who renounced American citizen-ship did not have a right to get it back.


Aleinikoff, Thomas Alexander. Semblance of Sovereignty: The Constitution, the State, and American Citizenship. Cambridge, Mass.: Harvard University Press, 2002.

Bates, Stephen. "Reinvigorating Citizenship." Society 36, no. 3 (March–April 1999): 80–85.

Clarke, Paul Barry, ed. Citizenship. Boulder, Colo.: Pluto Press, 1994.

Denvir, John. Democracy's Constitution: Claiming the Privileges of American Citizenship. Urbana: University of Illinois Press, 2001.

Preiss, Byron, and David Osterlund, editors. The Constitution of the United States of America: The Bicentennial Keepsake Edition. New York: Bantam Books, 1987.

Shklar, Judith N. American Citizenship: The Quest for Inclusion. Cambridge, Mass.: Harvard University Press, 1991.

Smith, Rogers M. Civic Ideals: Conflicting Visions of Citizenship in U.S. History. New Haven, Conn.: Yale University Press, 1997.

Kirk H.Beetz

See alsoConstitution of the United States ; Indian Citizen-ship ; Naturalization ; Suffrage ; Women, Citizenship of Married ; andvol. 9:President Andrew Johnson's Civil Rights Bill Veto .


views updated May 14 2018


Citizenship is the status of being a legally recognized member of a nation-state or other political community, possessing rights such as voting and owing duties such as jury service. In democratic thought, citizens generally are expected to be more actively involved and influential than citizens of authoritarian political systems. By joining environmental organizations, writing letters to government officials, working as volunteers, and otherwise affecting civic life, millions of citizens have helped bring about improvements in environmental policy, AIDS-HIV treatment, civilian nuclear power, genetically modified foods, and other technological endeavors.

In the city-state of ancient Athens, members of the demos participated directly in public debates and governmental choices, a time-consuming responsibility and honor—but only for the minority of the adult population who were not females, slaves, or otherwise excluded. When democracy was reinvented on the scale of the nation-state in Western Europe and the United States, citizenship extended only to property-owning males. Although such legal constraints have been abolished, the affluent and well educated continue to participate at higher rates, donate more money to candidates, and speak and write more persuasively. Women are underrepresented in political life due to the legacy of being hindered in "their access to full citizenship (including their capacity to speak and write freely, to acquire education, or to run for political office)" (Kessler-Harris 2001, p. 3–4). Ethnic minorities are disadvantaged almost everywhere.

New Citizenship Problematics

Challenges for citizenship now arise from globalization and the erosion of national sovereignty. The governmental unit one should identify with—the city of Paris, the nation of France, the European Union, or humanity most generally—is no longer clear (Balibar 2004). Because technological innovation emerges primarily in the affluent nations, moreover, those who reside elsewhere—a majority of humanity—in some respects are not citizens of the technological world order. Transnational citizenship seems increasingly sensible, therefore, yet institutions for it are weak.

Citizenship also becomes less salient when technological choices occur via the economy more than via government. Business executives exercise primary discretion over job creation, quality of work life, and new technological products, and computerized transactions in a few financial centers such as London affect monetary matters worldwide (Dean 2003). The privileged position of business extends to ordinary politics, where industry executives marshal unrivaled expertise, enjoy easy access to public officials, and have ample funds for lobbying and for legal challenges to government regulations (Lindblom and Woodhouse 1993).

In contrast, most adults work in semiauthoritarian organizations and exert little influence over whether technological innovations are used to make jobs more interesting, or to displace and down-skill those affected. Workers may learn a more general lesson: Don't expect to be full citizens whose opinions are valued and influential. Industrial democracy in the former Yugoslavia, codetermination laws in Scandinavia, and other experiments in economic democracy have not been widely emulated (Dahl 1985).

To the extent that ordinary people do participate in economic-technological choices, it is via consumer purchasing or market voting. Thus new homes in the United States grew from 800 to 2,300 square feet from 1950 to 2000, affecting energy usage, environmental despoliation, and even the level of envy. Consumer-citizens catalyzed global proliferation of a high-consumption lifestyle including air conditioning, television, and leisure travel—thereby distributing endocrine-disrupting chemicals throughout the biosphere, causing the extinction of several thousand languages and traditional cultures, endangering myriad species, and increasing rates of psychological depression.

The Challenge of Technoscientific Expertise

Another difficulty confronting citizenship is that technical knowledge increasingly required for informed discussion. When a U.S. congressional committee considered tax credits to help professional cleaners switch away from the dangerous solvent perchloroethylene in 1999, not a single citizen or public interest group wrote, phoned, or visited: Hardly anyone understood the problem of toxic air pollution from professional cleaning. Technologists do not themselves control governments, but expertise complexifies and effectively restricts participation in governance (Laird 1993).

A subtle way this occurs is that technoscientists accelerate innovation to a pace that government regulators, interest groups, and the attentive public cannot match. Roboticists, developers of esoteric weapons, biomedical researchers, nanotechnologists, and others ride a juggernaut fundamentally altering everyday life worldwide. If representative processes do not apply to technologists—most of whom are upper-middle-class males from the European Union, Japan, and the United States—and if there is insufficient time for deliberation, what meaning does citizenship have?

For all the shortcomings of traditional democratic procedures, that realm at least has competing parties, electoral campaigns, interest groups, and other forms of public inquiry, advocacy, deliberation, and dissent. Consumer-citizens enjoy none of these advantages—for example, shoppers rarely hear informed, conflicting views about environmental and other public consequences of products they purchase. Should citizenship be extended to the technological-economic sphere? To do so might require a set of citizen rights and obligations to "reconcile democracy ... with the right of innovators to innovate ... (and) to reconcile technology's unlimited potentials for human benefit and ennoblement with its unlimited potentials for human injury, tyrannization, and degradation" (Frankenfeld 1992, p. 462). Citizens arguably deserve relevant information, informed consent, and a limit on endangerment; and they presumably should embrace a corresponding duty to learn enough to exercise informed judgment.

In the early twenty-first century, technoscientists often proceed without obtaining informed consent, publics are mostly quiescent, and decision-making processes are not designed for timely deliberation. Extensive political research and development would be required to develop new mechanisms for holding technoscientific-economic representatives accountable, while organizing intermediary institutions to assist citizens in gaining requisite knowledge and shouldering other burdens of responsible participation.

There are a few encouraging signs: Some European political parties now require that women occupy 50 percent of elected offices, international norms and governance mechanisms may be emerging, and small-scale experiments with consensus conferences and other participatory innovations are gaining credibility. Nevertheless no innovation without representation is a long way from becoming the twenty-first-century equivalent of American colonists' cries against taxation without representation; there are formidable obstacles to an ethically defensible citizenship for wisely governing technoscientific trajectories and for fairly distributing rights and duties in a technological civilization.


SEE ALSO Civil Society;Consensus Conferences;Democracy;Expertise.


Balibar, Etienne. (2004). We, the People of Europe?: Reflections on Transnational Citizenship. Princeton, NJ: Princeton University Press.

Beiner, Ronald, ed. (1994). Theorizing Citizenship. Albany: State University of New York Press. Widely cited text that nevertheless fails to theorize the problems that science and technology pose for citizenship.

Dahl, Robert A. (1985). A Preface to Economic Democracy. Berkeley: University of California Press.

Dean, Kathryn. (2003). Capitalism and Citizenship: The Impossible Partnership. New York: Routledge.

Frankenfeld, Phillip J. (1992). "Technological Citizenship: A Normative Framework for Risk Studies." Science, Technology, & Human Values 17: 459–484.

Kessler-Harris, Alice. (2001). In Pursuit of Equity: Women, Men, and the Quest for Economic Citizenship in 20th-Century America. New York: Oxford University Press.

Laird, Frank N. (1990). "Technocracy Revisited." Industrial Crisis Quarterly 4: 49–61.

Lindblom, Charles E., and Edward J. Woodhouse. (1993). The Policy-Making Process, 3rd edition. Englewood Cliffs, NJ: Prentice Hall.

Lister, Ruth. (2003). Citizenship: Feminist Perspectives, 2nd edition. New York: New York University Press. Analyzes gender and citizenship in terms going beyond women's participation.