Accountability of PM -difference

Theme 1

Removal thresholds 

US 1

Though both system hold formal mechanism to remove head of gov, in practice, UK PM removed far more readily than US president.  

 

US presidential removal requires 2/3 senate conviction (-Article I section 3). That high threshold acquitted Trump in both 2019, 2021, and has never successfully removed a President. 

UK 1

Truss’ 49 day premiership ended after a loss of party confidence in Oct 2022 (the shortest PM tenure ever), demonstrate how party confidence operating as informal mechanism (conventional bar) to remove PM. 

-this is because UK operate in a fusion of power system (executive derives from largest party in HoC, with party leader being the PM. So loss of confidence from respective party result in removal of party leader, with it removal of PM) 

Difference 1

Structural theory:  

-removal thresholds are set by constitution or convention.  

Difference: high constitutional bar that produce no US presidential removals vs low conventional bar that produce frequent UK PM removal. 

Theme 2

Effectiveness of blocking legislation 

US 2

Though both legislatures possess formal power to block or amend gov legislation congress is generally more effective at constraining the executive than UK parliament.  

 

-Separation of power system in the US creates institutionally independent congress.  
President and members of congress are elected separately, and legislators are not dependent on president for their position (Presidents cannot sack legislators) 

Therefore they can oppose executive proposals and ensure legislative scrutiny.  

UK 2

By contrast, the UK operates under a fusion of powers system, where the Prime Minister and Cabinet are drawn directly from the majority party in the House of Commons. Because the executive normally commands a parliamentary majority and can enforce discipline through the whip system, Parliament is often less able to resist government legislation. For example, Boris Johnson secured the rapid passage of the Internal Market Act 2020 by imposing three-line whips on Conservative MPs, limiting the likelihood of a backbench rebellion despite concerns over its implications for devolution. 

Difference 2

Therefore, structural theory suggests that Congress is more effective at blocking executive legislation because the separation of powers creates an independent legislature. In contrast, the fusion of powers in the UK tends to strengthen executive control over Parliament, making legislative defeats less common when the government possesses a stable majority. 

Theme 3

Senate confirmation vs PM prerogative  

US 3

Trump’s cabinet appointments require Senate confirmation. For example, Pete Hegseth faced scrutiny and contested confirmation votes before taking office. 

UK 3

In contrast, Starmer appointed his cabinet in July 2024 without any parliamentary approval process. The Prime Minister can appoint ministers through prerogative powers without requiring a vote in the House of Commons. 

Difference 3

Cultural theory:  

In the United States, political culture has traditionally been suspicious of concentrated power, so Senate confirmation hearings are seen as an important way of checking presidential appointments before they take effect. 

In the United Kingdom, political culture has traditionally emphasised responsible party government. Once a Prime Minister has won the confidence of the House of Commons, it is generally accepted that they should be free to choose their own ministers. Accountability is expected to occur after appointment through parliamentary scrutiny rather than before. 

Therefore, Americans tend to favour pre-appointment legislative scrutiny, whereas the British system places greater emphasis on post-appointment accountability through Parliament.