Why Don’t Other Countries Have Government Shutdowns?

With the clock ticking down to an April 8 deadline and President Barack Obama and congressional leaders unable to resolve disputes over abortion funding and changes to the Clean Air Act, it appears more and more likely that the U.S. federal government is headed for a shutdown. If the shutdown were to continue through Monday, hundreds of thousands of federal workers deemed nonessential would be furloughed. Essential services, such as national defense, would continue, but soldiers would likely not be paid. Other important services such as benefits for veterans and clinical trials at the National Institutes of Health would also probably be suspended. Do other countries ever have to deal with this?

No. Other countries may have coups, revolutions, and collapses, but a government so deadlocked it simply ceases to function seems to be an exclusively American phenomenon. Several features of the U.S. political system — a strong executive branch with veto power, the Senate filibuster — make the sort of deadlock we’re seeing now more likely. In a parliamentary system, used by the vast majority of democracies in Europe and Asia, the budget process is similar on paper: The prime minister prepares a "government budget" and submits it to parliament for a vote. But if parliament rejects that budget, that’s generally considered a sign that the government no longer has the confidence of parliament and has to resign.

This is exactly what happened in Portugal last month, when Prime Minister Jose Socrates stepped down following the rejection of a new budget featuring harsh austerity measures. The country is currently under the leadership of a caretaker government, until new elections can be held and a new government is formed — which will presumably try to pass its own pared-down budget. However, just because a country with a parliamentary system is "without a government" doesn’t mean that government services stop. Thanks to robust and apolitical civil services, most governments can keep operating no matter who’s in power. Belgium hasn’t had a government since June 2010, but, for the most part, the trains still run on time, the trash gets picked up, and budgets are even passed.

U.S.-style shutdowns are theoretically possibly in a parliamentary system if a budget is rejected and the government doesn’t step down — but they never actually occur. There were fears not long ago that if Japanese Prime Minister Naoto Kan’s government proved unable to pass a budget by the start of the 2011 fiscal year in April, payments to civil servants and some government administrative services could be suspended. But the crisis was eventually averted when the budget passed in the wake of last month’s deadly earthquake. Battles over a series of related spending bills are still pending.

Even governments that are structured more along American lines, with strong executive braches, don’t seem to have budget disputes so fraught that they shut down. Brazil started 2008 with no budget after former President Luiz Inácio Lula da Silva’s spending plans were rejected by Congress, but there were no disruptions to government services. (Swine flu did succeed in shutting down most of Mexico’s public services in 2009.)

In fact, the shutdown has only been a feature of U.S. politics for the last 30 years. The Anti-Deficiency Act, originally enacted in 1884, prohibits federal agencies from conducting activities or entering into contracts that haven’t been fully funded by congressional appropriations. But for most of the country’s history, federal agencies simply continued operating during funding gap periods while trying to minimize unnecessary expenditures, believing that the law didn’t intend for them to shut down entirely.

In 1980, however, Jimmy Carter’s attorney general, Benjamin Civiletti, issued an opinion interpreting the act more narrowly to require that agencies suspend operations until a new appropriation was passed by Congress. Since then, there have been five shutdowns: two under Ronald Reagan that lasted for just a few hours, one under George H.W. Bush that conveniently fell over a holiday weekend, and two under Bill Clinton that lasted for five and 21 days — during which an estimated 800,000 federal employees were furloughed. A number of state government shutdowns have also taken place. In 1990, Congress passed legislation to ensure that vital services such as law enforcement and defense keep operating during funding gaps.

As with the current crisis, Congress has often put off government shutdowns through the passage of temporary funding bills called continuing resolutions. Some reform proposals have suggested making the passage of these resolutions automatic during funding gap periods. This might be a relief to thousands of federal employees and those who depend on their services — but would be a real setback to one uniquely American tool of political brinksmanship.

Thanks to George Guess, co-director of the Center for Democracy and Election Management at American University; Allen Schick, professor at the University of Maryland School of Public Policy; and Bingham Powell, professor of political science at the University of Rochester.