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Multiculturalism and immigration: A comparison of the United States, Germany, and Great Britain


If there is one general conclusion to be drawn from these case histories, it is this: having accepted significant numbers of immigrants at one point or more in the postwar period, liberal states had to tolerate the multicultural transformation of their societies. This is because liberal states, while nominally tied to particular nations, are still hesitant to impose particular cultural ways on their members. Liberal states are neutral vis à vis substantive life forms and world views, which proved to be the major inroad for multiculturalism. This communality of liberal states is revealed, shock-like, if one compares them with the illiberal, increasingly immigrant-receiving states of the Near and Middle East or East Asia: states that practice caning of illegal entrants and forced repatriation of labor migrants. This does not mean that, in confrontation with radical challenges to its very premises, liberalism can itself turn into a “fighting creed,” as Charles Taylor put it. This it did during the Rushdie Affair, which remains the most dramatic demonstration of the limits to multiculturalism in a liberal society. The “British liberties” held against protesting Muslims was “liberties” first, and “British” second - the national marker being exchangeable, the commitment to universal (Western) principles like freedom of speech and expression empathically not. As a result of the multicultural challenge, Western nations are increasingly stripped of their particular cultural contents and reduced to civic communities committed to the same procedural rules. This is why a second-generation Turkish-German intellectual could say that immigration offered a (however ignored) “opportunity” for the German nation to ease its historical burdens. In summary, liberal states have multiculturalism, because they have given up the idea of assimilating their members beyond basic procedural commitments.

Such empirical multiculturalism, while heavily reinforced by immigration, is in principle independent of the latter, and applies equally to non-migrant minorities, such as sexual or religious ones. However, multiculturalism proper is not just an empirical description of culturally diverse societies, but also a normative claim that cultural difference is to be publically recognized and instituted, and thus to be made the business of state rather than of private initiative. To this an exasperated Jürgen Habermas responded that “the ecological perspective on species conservation cannot be transferred to cultures,” insisting on the group-indifferent neutrality of modern law. Such normative multiculturalism, according to which the state is to be more than neutral, but actively protective of cultural difference, is especially problematic if applied to migrant minorities. “When in Rome, do as the Romans do” is one of the oldest and constant expectations that settled groups have brought against nomadic ones. The liberal state has in fact abandoned the factual “this is how we do things here” in favor of abstract civic rules to be followed by everyone equally. But multicultural claims for group rights, which tend to be backed by an anticolonial critique of host-society institutions, go beyond expectations for equal treatment toward preferential treatment for migrant “minority” groups. This is no easily sellable package, and its rejection seems partially to fire the current immigration cum affirmative-action backlash in the United States.

There is a tendency in the discourse of immigrant-rights groups to stress the forced, involuntary character of contemporary migration, which would make migrants deserving of compensatory treatment. “Migration was not black people chosing to come to this country, they were brought here,” says a London based “anti-racist” activist of Pakistani descent. “Me and a lot of other people wouldn't be here if it wasn't for the war... and the U.S. backing governments in El Salvador and Guatemala,” says a Los Angeles-based immigrants advocate from El Salvador. In academic discourse, an influential study held the “internationalization of production” responsible for postwar labor migrations, so that “the current phase of U.S. immigration” appears as “a domestic consequence of U.S. activities abroad.” Such reasoning does in fact reflect important, quasi-involuntary aspects of contemporary migrations, which resulted from the devolution of empire, civil war and foreign military intervention, and capitalist globalization. But within multicultural discourse, they are radicalized into debatable calls for “open borders” to have the exploited south partake of the riches of the exploiting north, while depicting migrants as victims with “home plus” entitlements, i.e., entitlements to diasporic homeland resurrection and host-society benefits.

Multiculturalism entails two opposite visions, articulated by its respective proponents and opponents: syncretism and fragmentation. The syncretist vision is eloquently outlined by Salman Rushdie, who sees mass migration as a possibility to “(celebrate) hybridity, impurity, intermingling, the transformation that comes from new and unexpected combinations of human beings, cultures, ideas, politics, movies, songs,” the migrant condition as a “metaphor for all humanity.” In this benign vision, multiculturalism realizes the old enlightenment dream of the unbounded “perfectibility of the human race.” The postcolonial literary imagination of Rushdie or Vikram Seth, popular “world music,” or the vibrant art world of Los Angeles give a hint of the syncretist riches of multiculturalism.

But in the realm of politics, multiculturalism is more likely to entail the less benign vision of fragmentation. Post-riot Los Angeles, with its bitter inter-ethnic competition among Blacks, Koreans, and Latinos for scarce “rebuilding” resources, and with its dismal trend towards colorconscious “Balkan justice” in the legal system, gives a hint at the seamier side of multiculturalism. In fact, the current flurry of interracial activism tries to put back together what multiculturalism has helped to tear apart. In his bleak survey of ethnocentric “identity politics” in various arenas of American polity and society, Jim Sleeper seeks to distinguish between “benign multiculturalism” and “dangerous ethnocentrism.” However, multiculturalism itself cannot generate the “civic” commitments that would allow people to transcend narrow ethnic-group boundaries. Here it is worth pointing out that citizenship and “civic culture” have historically been tied to the institution of nationhood as the fixpoint of an individual's highest loyalties. When he discussed the evolution of citizenship rights in modern Britain, T. H. Marshall mentioned in passing that it was tied to the development of “national consciousness.” Citizenship, says Marshall, requires a “sense of community membership.” Historically, this “community” has been the nation. If multiculturalism challenges the nation, it fails to offer a substitute for it. In this regard, recent analyses of “postnational” citizenship may be precipitous. Yasemin Soysal argues that European guestworkers have pioneered a new form of membership based on a transnational “logic of personhood” superseding the “logic of national citizenship.” But she has to admit that the implementation of “universalistic rights” remains “tied to specific states and their institutions.” Short of a world state, the world's states will remain nationstates. Paradoxically, multiculturalism remains dependent upon the nation-state, while undermining it at the same time.

What specific conclusions can we draw from our three case histories? We saw that in each case the three dimensions of multiculturalism: challenge to the nation, quest for group rights, and anticolonial perspective, are combined in different orders of priority. The quest for group rights and the anticolonial perspective are inherently linked, because claims for public recognition and special compensation are justified in reference to prior acts of external (as in the United Kingdom) or internal (as in the United States) colonization. The United Kingdom has stopped short of instituting “color-conscious” minority policies, but under the name of “equal opportunities” quasi-affirmative action is informally practiced in the provision of council housing, public employment, and schooling, especially at the local level. In the United States, the anticolonial perspective has first been adopted by the Black Power movement, which provided a model for other ethnic movements. While entirely justified in the case of blacks, whose enslavement is the original sin that haunts American society today, the anticolonial perspective fits less easily for migration-based ethnic groups. But their leaders have every incentive to exploit the affirmativeaction framework of the civil-rights era, because this happens to be the game with the biggest benefits in town. This entailed attempts by Indo-Americans - whose educational attainment and per-capita income exceed those of average Americans - to become a certified minority, which would make them eligible, among other things, for small-business loans and government priority contracts.

In Germany, the anticolonial perspective and parallel group-rights claims are largely absent. There is now little inclination in this country for disparaging the West, which had once been a recurrent theme in its traumatic history. German intellectuals are unabashed advocates of universalism, and they connote with the word “race” not the oppression of whites over blacks, but the killing of the Jews. Claims for minoritygroup rights are muted, because they have historically been related to ethnic homeland stances - of Danes and Serbs in Germany, and German minorities in Eastern Europe. Recently, Turkish migrant groups have sought to apply this framework of “minority protection” (Minderheitenschutz) to Turks in Germany, but the German left is divided about following them because of its völkisch connotations. In contrast to the United States and Britain, in Germany multiculturalism is almost exclusively a debate about national identity. But so entirely has nationhood been discredited by Nazism, at least for the German left, that multiculturalism went beyond redefining toward abandoning nationhood altogether as the basis of a liberal state. This led to a peculiar polarization between defenders of unreconstructed ethnic nationhood and a postnational left, in which the main task: the quick and easy transformation of foreign migrants into German citizens, remains unresolved. Demands for local voting rights or minority protection bracket the main problem for second- or third-generation immigrants in Germany: access to citizenship. A close observer of the German immigration debate says: “The crucial question of citizenship is skillfully avoided by all, including the left. No one likes to answer the question, Does an immigration country have the right to turn migrants into its own citizens (Einheimische)? American-style jus soli amounts to a form of forced citizenship (Zwangbürgerschaft). This is what no one dares to admit.”

In the United States and Britain, multiculturalism is less entangled in debates about national identity. Despite its postwar trend toward ethnic contraction, Britain itself is a “multicultural” agglomerate of nations, which leaves it ethnically underdetermined and in principle ready for additional ethnic fillings. Its imperial tradition, however, sets limits for a positive sense of Britishness among its former colonial subjects. Many of them identify themselves, in a mixture of irreverence and plain description, as “Black British.” The United States is distinct from the other two cases, because it alone has made the immigrant experience part of its national identity. In a mighty counterpoint to ethnic studies and all that, the bonds of the American “new nation” are recreated by every single immigrant who is turned into a citizen. Except among multicultural extremists, a positive sense of Americanness has not been lost. A young lawyer and ethnic activist of the Mexican-American Legal Defense Fund in Los Angeles, the daughter of illegal Mexican migrant workers who has gone on to Harvard and Berkeley, says what a second-generation immigrant in Berlin or London could never say: “We (second-generation Mexican immigrants) also feel very strongly that we are American.” If the next century will be a century of immigration, the “American Century” may be up for a renewal.

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Joppke, C. Multiculturalism and immigration: A comparison of the United States, Germany, and Great Britain. Theor Soc 25, 449–500 (1996).

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