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Volume 5.2 1997
ISSN 1048-3721
This page was last updated on 03/15/99



Miriam Feldblum

Today matters of citizenship have become increasingly salient and complex. Consider the following developments. The first is the recent creation of a supranational citizenship in Western Europe. In 1992 the Maastricht Treaty of the European Union (EU) created the status of European Union citizenship. Every citizen of an EU member state is now also a citizen of the European Union. This supranational citizenship has its own set of rights and benefits, including the right to vote and present oneself as a candidate in European and local elections wherever one lives. Thus, a French national in Hamburg can vote in the local elections as well as in the European elections for the European Parliament. In spite of several key dissimilarities between European and North American regional integration, one can try to imagine a future equivalent of a NAFTA citizenship, encompassing the nationals of Canada, Mexico, and the United States.1 Does a supranational citizenship displace national citizenship? Does it presume or enable transformations in citizenship practice and engagement?

A second development is the increasing number of dual nationals, that is, state reforms to permit dual nationality, and public efforts by immigrant activists in European countries and the United States calling for the right to dual nationality. Multiple nationality has traditionally been discouraged and banned by states. Nonetheless, its incidence is increasing. In part, transnational migration and the settlement of immigrants and their families, who retain the nationality of their countries of origin, account for growing numbers. Moreover, there are an estimated 18-19 million legal foreign residents living in Western Europe today (up from 5 million in 1950), so the incidence of dual nationality will certainly increase. In part, numerous West European states in the past decade or so have changed their laws, both in terms of facilitating the acquisition of citizenship and in enabling dual nationality. Indeed, one scholar has asserted that "the availability of dual citizenship has now become a matter of course in Western Europe."2 Even those states long opposed to dual nationality have softened their opposition. With 2 million Turks, Germany, a state known for its opposition to dual nationality, has recently engaged in interstate discussions with Turkey about making available such a status.3

In the United States, as well, the incidence of dual nationality is on the rise. While the United States has remained in principle opposed, numerous countries with large émigré populations in the U.S., including the Dominican Republic, Ecuador, Columbia, Ireland, and Poland, have permitted the acquisition of dual nationality.4 In Mexico, where there had been formal opposition to dual nationality, the Mexican government finally approved legislation in December 1996 permitting dual nationality. Today, there are over 1 million Mexican-born citizens of the United States who could regain their Mexican nationality, plus approximately 4 million Mexican-born nationals in the U.S. who are eligible for naturalization and will now be able to retain their nationality of origin, as well as another 2 million undocumented Mexican immigrants. Mexican immigrants in California, like Turkish immigrants in Berlin, have engaged in their own campaigns for a series of simultaneous rights, including the right to dual nationality, the right to vote in their countries of origin from abroad, and still again, for the extension of local voting rights for nonnationals in their place of residence.5 Given this emerging fluidity of memberships—local, national, and transnational—are citizenries still defined as bounded by one state border or identity?

But, does a single citizenship itself anymore imply a singular loyalty or identity? Besides the incidence of dual citizenship, a third major development has been the proliferation of citizenship reforms in Europe—some highly politicized, some expansive, and some restrictive, many seemingly flouting long traditions of citizenship held in those polities. In the U.S. presidential elections in 1996, proposals to deny citizenship to children born of illegal immigrants gained visibility. More generally, the United States and Europe have featured a proliferation of politics conflating issues of citizenship and immigration, in particular of immigrants, national membership, and identity.

In 1994 the intensive politics around Proposition 187 in California epitomized this kind of conflation. Proposition 187 was ostensibly an effort to prohibit so-called illegal immigrants the right to access an array of state and federal benefits as well as to strengthen state powers to identify and detain these immigrants. Yet, the lines between illegal immigrants, legal immigrants, and citizens of immigrant origin were often blurred. A cartoon, drawn during the Proposition 187 debates and entitled, "Can You Spot the Illegal Immigrant," exposed the overlap. The cartoon featured a line-up of five: an overstayed tourist, an illegal nanny, an overstayed student visa, an illegal Irish businessman, and a citizen (wearing a VIVA MEXICO T-shirt). Now, the cartoon takes note implicitly of the widespread awareness of the realities of transnational loyalties and memberships—a Viva Mexico shirt to identify an American citizen—and explicitly of adverse reactions to these realities.

In Europe, the transnational identities of current migrants—their origins and religion—have become highly visible as well. There are now 10-13 million Muslims living in Western Europe, a significant portion of whom are nationals of European countries; the largest populations are 5 million in France, of whom at least 2 million are French nationals or dual nationals; 1 million in Britain, of whom most are nationals; and 2 million in Germany, of whom almost none are nationals. During highly visible affairs—including the Rushdie affair in Britain and the Islamic scarves affair in France—the issue became in part the suspected transnational memberships and loyalties of resident Muslim populations. If we consider the California cartoon once again, it is evident that the linkage between citizenship and immigrants is mediated by concerns of membership, because certain immigrants—whether illegal, legal, or even citizens—are considered foreign and "illegitimate," be it origin or religion that is rendered suspect.

The final development I want to highlight is the accumulation of rights and benefits for which noncitizens are now eligible, in effect, citizenship rights without citizenship. The efforts of Proposition 187 in California, other state efforts, as well as the sections of the federal welfare reform act passed in October 1996 (the Personal Responsibility Work Opportunity Reconciliation Act) dealing with both legal and illegal foreign residents currently in the United States, are aimed to rescind those rights. They are at once an acknowledgment and reactionary response to postwar trends visible in the U.S. and Europe, which have consistently enlarged the scope of rights and benefits to nonnationals even as the expected duties and obligations specific to nationals have diminished.6 In Western Europe, long-term foreign residents have the economic, legal, and social rights of citizens, including rights to welfare, social service, unemployment, and medical insurance. While European Union citizenship covers nationals of those member states, several European states had already extended local suffrage rights to all foreign legal residents. For many foreigners and immigrants, the goal is permanent residency; not citizenship. Rather than assume great differences between citizens and permanent foreign residents, the reality in European states and the United States appeared to be that citizenship didn’t matter. Or, was it alternatively that foreign residents became de facto citizens?

Let me summarize the developments sketched above. They are the creation of a supranational citizenship, the increasing incidence of multiple citizenship, proliferation of citizenship reforms or politicized membership politics, and finally the trend of citizenship rights without citizenship. These developments stand in stark contrast to the traditional order of citizenship, where citizenship was the bastion of the nation-state and consequential for a variety of reasons—it was the basic element of national sovereignty, of political identity, of one’s rights, benefits, and duties, of one’s community and culture. When we look at contemporary membership, it no longer appears to be simply a domestic issue, where what is contested appears to be exactly identity, rights, and national community and culture.

This article provides one reading of the contemporary transformations in citizenship, drawing from developments in Europe and the United States. The article is not comparative in nature, but rather aims at a broader understanding of the contradictory forces shaping and changing citizenship practices and policies. I argue two central points. The first is that national citizenship is, in fact, being reconfigured, in the direction of what has been called "post-national membership."7 By post-national, I refer to developments that move beyond the formal state, or where the state is no longer the important site for citizenship. My second argument, however, functions as a brake on the first point. Because while I do contend that citizenship or membership now has post-national features, I also argue that we would be wrong to conclude that the transformation in citizenship can be understood as a conflict simply between the old national form of membership and new, emergent post-national forms of membership.

Instead of a dichotomy between state citizenship and post-national citizenship, there is, in fact, another set of processes shaping citizenship today, which I call here neo-nationalist. By neo-nationalist, I refer to developments whose effects are to reconfigure cultural, national, and transnational boundaries and ensure closure. In order to understand these two new sets of developments, post-national on the one hand and neo-nationalist on the other, which overlay the old order of state citizenship, I contend that we need to examine both how citizenship politics are constructed in each state and the interplay of domestic and international politics. In addition, I argue that we can understand new developments in terms of changing citizenship strategies, or in other words, in terms of the function of citizenship practices.

The article is divided into three parts. I begin with a brief review of how citizenship has been understood and organized historically and outline four central dimensions of the traditional order of state citizenship. In the second section, I analyze the emergence of post-national membership and discuss the extent to which post-national outcomes and strategies are shaping contemporary citizenship practices. In the third section, I then focus on the extent to which neo-nationalist trends and strategies are shaping contemporary citizenship development. The conclusion is a reflection on the implications of these seemingly contradictory trends.


Traditionally, citizenship has meant full membership in a polity. In the modern world, the polity is understood to be a nation-state, that is, citizenship is integrally linked to a territorial state and to the people (or nation) belonging to that state. The historical and analytical distinctions between citizenship and nationality arise in the modern overlay of membership in the nation (nationality) and active membership in the political state (citizenship). For my account here, I wish to focus on four central dimensions of state membership: the regulation of citizenship, the institutionalization of citizenship, the ideology of citizenship, and the locus of citizenship.

The first dimension of nation-state citizenship is the regulation of citizenship, those formal state membership policies that set the institutional procedures and legal parameters of state membership and tell us, if only in a technical sense, who is a formal citizen or national of this state. These include nationality and citizenship laws, naturalization laws and procedures, rules governing dual nationality, and the attribution, acquisition, and loss or forfeiture of nationality.

Variation in these rules certainly existed, and continues to persist. Consider, for example, rules governing the automatic attribution of citizenship status by the state. A comparison of the United States, Germany, and France demonstrates marked variations. In the United States, territorial criteria or the rule of jus soli govern the attribution of citizenship; citizenship is attributed to all born in the territory. It is this rule that is being questioned by recent advocates of the denial of citizenship to children born in the United States to illegal aliens.

In Germany, citizenship traditionally is based on lineage criteria or the rules of jus sanguinis. According to the 1913 German nationality law, one is automatically attributed German citizenship if one’s parents or ancestry are German; if not, then a procedure of naturalization must be undertaken. These are the rules governing the attribution of German citizenship to "ethnic Germans" from Russia and other parts of Eastern Europe; they are granted citizenship automatically upon entry into Germany. At the same time, second- or even third-generation immigrants of Turkish origin born in Germany are neither attributed citizenship at birth nor automatically given it at any point later on; they must undergo naturalization and renunciation of their previous (Turkish) citizenship to obtain German citizenship. As will be discussed later in this article, these rules and distinctions have been questioned and somewhat modified by recent legislative and administrative reforms.

On the other hand, French policies were traditionally a mixture of territory and lineage. Since the nineteenth century, second-generation immigrants—those born in France of foreigners born elsewhere—in principle become French automatically at their majority; third-generation immigrants—those born in France of foreigners born themselves on French territory—were attributed French citizenship at birth. These rules governing territorial criteria have been the subject of debate and recent revision in France.

Despite the sharp dissimilarities of these three cases, all of their rules rely on the presumption of a citizenry bounded to the nation-state and a norm of a singular citizenship. In an administrative, legal sense these rules tell us who is a citizen. Thus, the regulation of modern citizenship implicitly has meant the regulation of single citizenship, and the coincidence of bounded citizenries and territorial nation-states.

The second dimension is the institutionalization of citizenship, which most often has been understood in terms of incorporation, rights, benefits, and obligations. The institutionalization of citizenship gave the status much of its consequentialness and underscored distinctions between nationals and nonnationals. It also underscored distinctions between effective, full citizens and those without full membership or effective citizenship. T.H. Marshall’s now classic statement of the development of modern citizenship as a status denoting full membership in a community and to which are attached rights and duties, delineated three distinct elements of full citizenship: civil, political, and social rights.8 Recently, some scholars have discussed the addition of "cultural" rights as elemental to citizenship.9 As with the regulation of citizenship, the rights and benefits associated with formal state membership have varied historically and cross-nationally. Moreover, the nature and determination of citizenship rights have been reconsidered since Marshall’s analysis.

For example, writing as a corrective to T.H. Marshall’s configuration of citizenship development, Michael Mann traced varied historical paths of citizenship practices as constitutive of different kinds of "strategies."10 Whereas Marshall identified change in the development of citizenship in terms of the consecutive enlargement of sets of rights (civil, political, social) and the extension of rights to different classes in the nation-state, Mann argued that such a pattern reflected only one kind of strategy. Mann, like Marshall, related the modern development of citizenship to national class conflict and efforts to institutionalize and control such conflict. But Mann used the concept of citizenship strategies to differentiate ruling class and regime action among the European states. He argued five different types of citizenship strategies were actually visible in different countries and at different points in time: "liberal, reformist, authoritarian monarchist, Fascist, and authoritarian socialist."11 Bryan Turner examined the extent to which citizenship strategies were constructed at different levels. He identified both state and collective strategies by showing "passive" and "active" variations in citizenship development and incorporation.12

Despite the dissimilarities in understanding the institutionalization of citizenship, what is useful to underscore is that in all of these studies it took place within the national parameters of a territorial nation or single state. The developments were driven by national agents, namely the state, the ruling economic and political class and other socioeconomic classes. They were a function of national conflict, whose specific patterns then were reflected in the state-citizenship nexus. They featured the deployment of national referents, including the single state, shared nationhood, and bounded rights. Overall, the strategies described by Mann and Turner, while more variegated than the one presented by Marshall, were mainly about incorporation of bounded citizenries into national citizenship.13

The third dimension of citizenship has been the ideology and understandings of citizenship. This dimension has encompassed substantive understandings of citizenship and its meaning; dominant idioms or discourses about citizenship and membership; the changing meanings of democratic citizenship; and finally, arguments about citizenship and the identity of its citizenry, community, or nation. For this essay, what is of interest is the linkage of substantive understandings of citizenship, and the identity tied to it. Europe and the United States have long featured marked variation. On one level, understandings and traditions of membership have varied due to different national histories and institutional contexts. For example, German citizenship has been characterized as ethnocultural because the identity and criteria of citizenship were historically tied to understandings of a German ethnic people, nation or Volk, which were not derivative of the national state. In contrast, French citizenship has been characterized as political-cultural because the identity and criteria of citizenship were historically tied, through the French Revolution, to understandings of the linkage between the state, national culture, and political community. These national histories, mythologies, and models often have served as the impetus for the study of citizenship as a matter of a series of national exceptionalisms.

On another level, the current exploration of the identity of national citizenship in the context of "new immigration" has drawn on varied, and often competing, substantive understandings of citizenship. Frequently, the burgeoning literature on the substantive dimensions of citizenship is embedded in questions about the extent to which contemporary immigrants pose a challenge to state citizenship and existing understandings of citizenship or about the relation between new or newly visible kinds of diversity and existing national memberships.14 If on the first level, citizenship was reduced to (mythic) models of national culture, on this level, citizenship often is bifurcated into competing understandings of liberal and communitarian membership.15

The current appeal of republicanist notions of citizenship on the one hand and multicultural notions of citizenship on the other is an example of this bifurcation. While both notions have appeared multifaceted and dependent upon context and intention, republicanist citizenship has drawn on the philosophical tradition of republicanism, more general communitarian and particularistic understandings of national membership, and membership anchored in formal state citizenship.16 Variations of multicultural citizenship have drawn on liberal, individualist definitions and alternatively on definitions encompassing collective and group recognition.17 Overall, however, multicultural citizenship traces its arguments to the liberal tradition of rights, multiplicity of immigrant identities as competing rights to national membership, and membership usually though not necessarily anchored in formal state citizenship.

The debates over multicultural and republicanist notions of citizenship, therefore, have been about liberal and communitarian perspectives, and the individualist and political cultural views that underpin their reasoning and argumentation.18 For the most part, despite their differences, both the liberal and communitarian views of modern citizenship have presumed that membership is situated in the nation-state, that citizenries are defined by these national boundaries, and that the consequentiality of substantive citizenship is derived from formal state citizenship.

Finally, the last dimension of state citizenship concerns the locus of national membership, namely, that the nation-state is understood to be the locus of authority deciding and organizing citizenship. In all of the dimensions of citizenship outlined above, the role of the state has been integral. The nation-state sets the boundaries for citizenship, ensures the bounded citizenry, enables the functioning of citizenship strategies in the national context, and perpetuates the distinctions between nationals and nonnationals. There is no variation here because there is no alternative to the state. There is no room for multiple sources of authority determining citizenship, granting citizenship, deciding rights.

The historical basis of these four dimensions of citizenship—regulation, institutionalization, ideology, and locus—has been the West European experience. As noted earlier, effective full citizenship was historically not granted to all peoples living in the state (e.g., working classes, women), but the development of national citizenship in Europe was generally characterized as the progressive extensions of effective citizenship to different groups and the progressive extensions of right and benefits (e.g., civil, political, social), all of which took place within the parameters of the nation-state, continuing the sharp distinction between citizens and noncitizens. Yet, the developments with which I started spoke of very different citizenship matters. What led from the coincidence of citizenship and the nation-state to contemporary outcomes? The first trend shaping citizenship that I want to examine is the emergence of post-national membership. Some of the transformations taking place point to new patterns of expansion and the diminishing of the formal linkage between the state, citizenship, and the identity and rights associated with that status.


One of the most striking trends in contemporary citizenship, especially in Europe, has been the proliferation of citizenship and nationality reforms and proposed reforms. These reforms are central to the first dimension of citizenship, namely the regulation of citizenship, in part through formal state policies. A large number of these reforms has facilitated citizenship acquisition, expanded the criteria for citizenship, and loosened restrictions against dual nationality. Belgium and the Netherlands, for example, revised their laws in 1985, supplementing their traditional descent and lineage-based criteria for membership with qualified territorial rights to citizenship; they also facilitated naturalization, extended local suffrage to long-term foreign residents, and enabled, by legal changes or practice, dual nationality. Germany has gradually liberalized its naturalization procedures and conditions for both long-term foreign residents and foreigners born and raised in Germany. A 1991 law gave these groups a claim to naturalization. The most recent revisions in July 1993 gave both groups an "absolute entitlement to naturalization."19

Expansionist reforms point in the direction of post-national membership in several ways: dual nationality reforms clearly break with the logic of single citizens, and reforms facilitating access to citizenship can modify the ties between national identity and formal citizenship. At the same time, by facilitating the acquisition of citizenship, states enable in practice the increasing incidence of multiple memberships. The reforms arose in the aftermath of postwar labor migration to Western Europe and acknowledged, albeit reluctantly and only recently in certain cases, permanent immigrant settlement in these polities. It is important to note that characterizing these reforms as expansionist and leading to post-national outcomes does not delimit the varied politics driving these reforms.

Consider more closely the phenomenon of dual nationality. The availability and normalization of dual nationality is a trend that bolsters new citizenship strategies, and which has contributed to the processes changing the traditional order of state citizenship. Dual nationality breaks with the logic and aims of prior national citizenship strategies; the parameters, conflicts, referents, and political agents are no longer simply congruent with the single state. Regardless of the intentions of policy makers, therefore, the proliferation and legitimating of dual and pluri-nationality transform the function of citizenship. For disparate sets of reasons, the European Parliament has called for EU member states to permit dual nationality; the Swedish and French governments struggled to rescind the 1963 Strasbourg convention in the Council of Europe; Portugal reformed its laws to permit dual nationality; Germany allows ethnic Germans [Aussiedler] who acquire German nationality to retain their previous citizenship; and recently numerous Turkish organizations in Germany have called upon Germany to accept dual nationality. The French efforts to rescind the Strasbourg convention were largely motivated by government officials and French emigrant groups who bemoan the inequities of the legitimate dual national status of a Franco-non-European, such as a Franco-Algerian, and the problematic dual national status of a Franco-European, such as a Franco- German. On the other hand, in 1981 Portugal loosened restrictions on dual nationality for its numerous emigrant groups abroad, who did not want to forfeit Portuguese nationality. Thus, post-national outcomes are not simply categorized by the intentions or by the aims of particular actors.

Understanding the processes constructing post-national outcomes is, in fact, critical for any reading of contemporary citizenship. Consider next the second dimension of citizenship outlined above, namely the institutionalization of membership by incorporation, rights, and benefits. The development of citizenship rights without formal citizenship has meant in formal and practical ways that state citizenship is less determinative, matters less. Tomas Hammar and other scholars have called these new rights, "denizen rights."20 Yasemin Soysal has argued that the enactment of legislation granting rights or facilitating incorporation on criteria other than formal citizenship status is indicative of an emergent post-national model of membership. Importantly, one of the bases for extending rights has rested on the notion of what Soysal has called "personhood": the foreigner is considered a person—a human—if not a national. Thus, the extension of rights for nonnationals is linked to the concurrent rise of human rights discourse in international and transnational regimes.21 This notion of personhood has been called a post-national norm insofar as it is not based on national status nor determined by the nation-state; however, the arguments and discourse about human rights need not originate outside the state. In European states, national courts have played important roles in striking down government actions to restrict rights and benefits as violating human rights of these people, regardless of their citizenship status. At the same time, international organizations have also called for the protection of the human rights of foreigner populations.

Other interpretations have classified contemporary policies granting "denizen-style rights" as extensions of national citizenship. For example, suffrage has been a right traditionally associated with formal legal citizenship. Rainer Bauböck has called the extension of voting rights an extension of citizenship. However, I would argue that the effect of these policies does not really extend citizenship to foreigners along the logic of national citizenship strategies. The extension of local suffrage to nonnationals translates into more fluid national boundaries but does not transform the status of foreigners into a status analogous to that of previously disenfranchised classes within these polities.

The ideology of citizenship, the substantive understandings and identity constituting national membership as a status, was the third dimension of traditional citizenship. As immigration and citizenship became politicized topics, immigrant activists and others have attempted to redefine the national identity and to talk about transnational loyalties or multiple memberships, rather than a singular citizenship. For example, the impetus of the idea to disassociate citizenship from nationality came from immigrant activists who advocated the right to engage in voting and other "citizenship" activities in the locality where they lived and yet wanted to retain their own nationality. If one considers this logic, it is evident that the disassociation by the European Commission of member-state nationality from member-state citizenship activity and residence is an integral part of the reasoning underlying the practice of European Union citizenship.

The recent appeal of multicultural and republicanist citizenship is another indicator of transformations in state citizenship. For example, the emergence of certain kinds of state multicultural policies can provide another example of how identity and incorporation are no longer situated at the level of the nation-state or within a bounded citizenry. However, the practice and definition of multiculturalism are not self-evident. For example, in describing multiculturalism in Australia, Stephen Castles argues that multiculturalism maintains that it is no longer necessary to be culturally assimilated to be an Australian citizen.22 Nevertheless, from an Australian perspective, and, more generally, from the perspective of traditional state citizenship, access to formal citizenship is the first step of multicultural citizenship. Indeed, in Australia and Canada, multicultural policies are closely linked to formal citizenship acquisition campaigns (e.g., the "Year of Citizenship" in Australia).

These multicultural policies can be usefully contrasted with multiculturalism in Germany. In Germany, many multicultural policies are tied to residence and activity, and not to a rhetoric of nationality or national integration, nor aligned with efforts of "national community." Consider a multicultural billboard put up by the Mayor of Solingen after the firebombing of a Turkish family’s house in which five women and children were killed—some of whom were second-generation immigrants in Germany. The board read:


mural.jpg (23298 bytes)
"Your Christ [is a] Jew Your auto, Japanese Your pizza, Italian Your democracy, Greek Your coffee, Brazilian Your vacation, Turkish Your numbers, Arabic Your letters, Latin And only your neighbor is a foreigner?"

On the one hand, the multiculturalism underlying this public campaign fragments and externalizes immigrant identity and so, in effect, de-politicizes their membership. On the other hand, the campaign assumes a "fragmentedness" and "foreignness" of cultures and so, in effect, bypasses the nation-state membership to configure a new model of post-national incorporation.

The domestic processes in Germany constructing citizenship politics provide future insight into the determinants of post-national transformations of citizenship. Post-national citizenship outcomes in Germany have been shaped, at least in part, by the interaction of historical rules, institutional practices, and political strategies. For example, Germany’s traditional understandings of membership presumed a strategy of maintaining a closed national community based on ethnicity, which has been largely de-legitimized (in part by human rights discourse), and by notions of nationhood (the German Volk tradition), which are not easily open to reconfiguration. On the other hand, Germany’s existing corporatist state structure has provided foreigner groups such as the Turkish population with collective recognition and social and economic incorporation into the existing order. Given their status and relation to the state, immigrant groups in Germany have pursued incorporation strategies that use their transnational linkages and resources, rather than those that have been aimed primarily at some type of national community—neither an open nor profitable alternative.23 From this perspective, post-national outcomes and strategies are arguably a coherent outcome of domestic political processes in Germany, even as they have been informed and influenced by international discourses and transnational regimes.

The last dimension of state citizenship has been its locus in the nation-state. Here too, new developments have highlighted the transformations taking place. Consider the creation of European Union citizenship once again. The locus of authority for European Union citizenship is not delimited to the nation-state, or the national state members of the Union. Part of the drive underlying the new EU citizenship has been that the European Union is giving its member nationals the new status to generate loyalty and identity to itself, to the European Union. From this perspective, EU citizenship can be considered not simply as complementing national membership but displacing national citizenship. As a whole, European integration process continues to shift decision-making upward. At present, much of the rules regarding labor flow, population movements, social policies, and rights are being defined at the level of European Union institutions, including the Commission, Council, and Court.

Post-national developments are not simply extensions of national development of citizenship because they break with its logic, they move citizenship beyond or outside of the parameters of a territorial nation-state; and, furthermore, they underscore how citizenries are no longer bounded as they once were. At the same time, even as post-national outcomes and strategies have been the product of both international and domestic processes, other outcomes and strategies have also arisen. In the next section, I argue that we can discern in current citizenship development the distinctive emergence of new nationalist strategies and outcomes. I call them neo-nationalist, because their effect is to reconfigure cultural, national, even supranational boundaries and ensure new closures (unlike the old national developments). Like post-national outcomes, this new set of developments and strategies is not simply the product of national variation, it has been shaped by cross-cutting transnational trends as well as specific domestic processes.


As with post-national processes, neo-nationalist developments can be examined in each of the central dimensions of citizenship. Despite the proliferation of expansionist nationality reforms, a competing development in the regulation of citizenship has been the rise of neo-nationalist strategies. The reinvigoration of state citizenship and state nationality reforms that aim to reassert the primacy and importance of national parameters and to revalue a bounded citizenry are indicative of neo-nationalist outcomes. Politically, efforts to restrict citizenship access and to define national membership in exclusivist, cultural nationalist terms have been visible across Western Europe and within the United States. These efforts are often spearheaded by far-right groups in Europe or rightist politicians in the United States, but the generation and promotion of culturalist rhetoric and restrictive access spans the political spectrum.

For example, in 1993, France culminated a ten-year national debate on citizenship with an important revision of the Nationality Code. The 1993 revision tightened France’s traditional territorial criteria for citizenship. It required that second-generation immigrants—those born and raised in France of foreign parents born elsewhere—file formal requests to become French in order to integrate into the French national community. The reform also restricted the applicability of other territorial criteria, which facilitated attribution of citizenship to its post-colonial populations. The effects have been significant, at least as evidenced by its implementation and usage in the first year: only half of immigrant youth actually completed the form affirming their wish to be French, which, in principle, they must do by the end of their period of eligibility to obtain French citizenship.

To what extent are the French transformations in citizenship neo-nationalist? Elsewhere, I have argued that neo-nationalist citizenship actually did become the dominant strategy in France by the late ’80s, with the most recent reform more an affirmation of that politics in place, rather than the beginning itself of a new political trend.24 It is important to note that new citizenship in France did not rely solely on the logic of the nation-state. The debates in France also drew on human rights discourse, on the right to difference, and on a culturalist Europe. Proponents of citizenship reform that stressed closure in France sought to reinvent the national tradition of citizenship using these new references; their discourse has been characterized as a "new nationalist republicanism."25

Why does France appear to feature neo-nationalist outcomes while Germany features post-national outcomes? Well, just as I sketched out why post-national outcomes and strategies in Germany have been shaped in important ways by domestic political processes, I would draw parallel arguments in the case of France. For example, the structure of French formal citizenship policies and its republicanist traditions were very conducive for cultural nationalist arguments; "republican nationalism" was constituted at once as political tool and legitimate analytical model in France. Furthermore, French statist organization diminished the opportunities for the recognition of immigrant populations as collectives and, to the contrary, encouraged the bifurcation of a political individualism in the national community and private identities. Thus, multiculturalism in France has been closely tied to the promotion of "national integration" of immigrants; it is explicitly not understood in terms of a multicultural public citizenship. Whereas in Australia it is the content of national citizenship that expands, in France the identity and transnational referents are redefined either to coincide with French cultural parameters or to be relegated as external to citizenship. French state multicultural policies have supported items such as "ethnic festivals" and at the same time insist on the public predominance of an individualist, distinctively French model of citizenship. In contrast to an incorporation that bypasses the nation-state, multiculturalism in France has the effect of reifying a putative national model of state citizenship. Immigrant strategies reflect this configuration of constraints and opportunities. For groups like France Plus, a Franco-Maghrebi electoralist association, the strategies are primarily integrationist and complement nationalist rhetoric, even when their frame of reference includes more transnational human rights or immigrant rights emphasis.

At the same time, if domestically neo-nationalist outcomes or strategies have been less feasible in some European countries than others, these states have pursued enclosure and boundary setting at other levels. For example, while Germany and other states have facilitated access to citizenship, they have dramatically closed off physical access to themselves. In 1993 Germany dramatically restricted its refugee policy. Indeed, across Western Europe we see a generalized series of efforts to tighten and restrict access into the countries, in other words, the phenomenon of a "Fortress Europe." Interestingly, part of that rhetoric derives its logic also from transnational trends often associated with post-national outcomes. Arguments for Fortress Europe have included reference to Europe’s right to be different, that is, its cultural and historical rights. The promotion of a culturalist Europe, in part, has been about the transnational discourse of rights and identity. Part of the rhetoric has also been based on the new political economy of the postwar order so that European states argue that they are responding in necessary ways to the pressures generated by the internationalization of markets and the globalization of labor. Arguments for Fortress America have translated into actual construction of a concrete fortress, walls and wire, with its foundation built on similar neo-nationalist logic.

As well, neo-nationalist citizenship has operated as a strategic response to post-national outcomes, such as postwar trends enabling traditional citizenship rights without citizenship. The variety of American efforts, including Proposition 187 in California and the new federal welfare reform act—the latter of which has entailed the removal of eligibility for legal foreign residents from a wide range of Federal benefit programs—have resonated powerfully in Europe. Recent European efforts include crackdowns against illegal immigration in numerous European countries in addition to specific efforts aimed at asylum seekers. In autumn 1995 the British Immigration and Asylum Bill called for restricted access to services for certain groups of asylum seekers and, similarly, the rightist German party, Christian Social Union (CSU), has called for payment cuts to refugees and asylum seekers.26 Thus, even when citizenship as a status has appeared to matter less, new patterns of exclusion have arisen, which are constituted by boundaries that are both within and without the nation-state, and where the most vulnerable groups are the asylum seekers.27 Indeed, as European polities have revised and restricted their refugee definitions and asylum procedures, and as they have sought to create a harmonized bloc (and block against potential refugees and asylum seekers), the numbers of asylum seekers has dropped dramatically in Europe over the past two years. Indeed, in 1995, with the exception of Great Britain, most West European states experienced a decline in the number of asylum-seeking applicants.28 In this respect, neo-nationalist membership strategies are not solely domestic. They have transnational implications as well as domestic consequences.

The transnational dimensions of neo-nationalist membership also lead to a reconsideration of post-national developments in the last dimension of traditional citizenship—namely its locus of authority. At first glance, European Union citizenship appeared as a clear example of post-national membership. Some scholars have argued that to speak of a European identity or citizenship challenges "nationalist conceptions of political citizenship."29 Yet, an alternative interpretation is also possible. European citizenship has been based on a strong presumption of national citizenship and, as well, has been most frequently understood as complementing the national memberships of its member states. In fact, to speak of a European citizenship or identity has usually been to construct Western Europe as an historical-organic collection of nation-states, which necessarily banded together to protect their cultural particularities.

European Union citizenship and European identity can be understood as a reformulating of nationalist ideas where the redrawing of the lines around a culturalist and physical Europe ensures the exclusion of non-European foreigners—an exclusion that could no longer be effectively or easily accomplished at the level of the nation-state. Neo-nationalist outcomes are not simply replays of old national development of citizenship; the logic is often different (e.g., human rights for cultural entities). The focus is on exclusion, not progressive extension, and the enclosures that are necessarily situated at the level of the nation-state. Neo-nationalist trends, in part, are a product of the same phenomena that have generated post-national outcomes as well as strategic responses to the post-national outcomes themselves.

What are the implications of these two trends? What I have sought to explicate in this article is that contemporary citizenship development features two emergent kinds of strategies and outcomes: post-national and neo-nationalist membership. These trends have had both domestic and transnational consequences. Furthermore, the interplay between the two trends is an ongoing process.

Herein lie the new dynamics of citizenship, located between a post-national world of increasing transnational linkages, transformed sovereignty, and fluid memberships, and a world of entrenched nation-states, new nationalisms, and protracted preoccupations with identity—one where the nature and practices of citizenship have changed. Post-national and neo-nationalist outcomes are both indicators of change and strategies of ongoing processes. Thus, even as citizenship is still perceived as the bastion of the nation-state, the array of changing citizenships signals turbulent and shifting fault lines.

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1 The Maastricht Treaty delineates the status and accompanying rights of EU citizenship in Article 8a to 8e of the treaty. Its stated intention for instituting the new status to "every person holding the nationality of a Member State" was to "strengthen the protection of rights and interests." Beyond suffrage rights, other benefits of EU citizenship include the right to travel and reside, the right to be represented by consuls of member states if traveling in third-world countries, the right to petition the European Parliament, and the right to complain to a European Ombudsman.

2 Dilek Çinar, "From Aliens to Citizens: A Comparative Analysis of Rules of Transition," in Rainer Bauböck, ed., From Aliens to Citizens: Redefining the Status of Immigrants in Europe (Aldershot: Averbury, 1994) 62.

3 It should be underscored that while many states, in principle, still oppose dual nationality, these states have experienced a rise in dual nationals. For example, it has been estimated that there are approximately 1.2 million German dual nationals. In certain German Länder, but particularly in Berlin, greater use of exceptions concerning renunciation of a prior nationality is in practice; thus, two-thirds of Turkish citizens applying for German citizenship in 1992 in Berlin (2,366 persons) were allowed to keep their Turkish citizenship. See Çinar 54.

4 In practice, the United States does not deny U.S. citizenship to dual nationals, does not require official notification that naturalized U.S. citizens have formally renounced their nationality of origin, and does not inform states of origin about the naturalizations in the U.S.

5 For debates about citizenship reform and dual nationality in Berlin, see "Euro-Foreigners have right to vote in Berlin Municipal Poll," Agence France Press 20 Oct. 1995; Alan Cowell, "Turks seek Acceptance of Culture in Germany," New York Times 14 Dec. 1995 and "For Turks, Life (or death) in Germany still offers no respite," New York Times 8 Dec. 1995.

6 Neither the extension of rights to nonnationals nor the diminishment of obligations for nationals are derivative from contemporary immigration. The causes of these mainly postwar trends have been both domestic and international, relating to state institutions, political processes, political economy, international politics, and changing international regimes. For example, President Chirac of France recently announced the possible end of national conscription in the country due, in part, to post-Cold War contingencies. See Craig R. Whitney, "Cold war over, France plans slim, volunteer military," New York Times 23 Feb. 1996: A3. For the extension of rights to nonnationals, see Tomas Hammar, Democracy and the Nation-State: Aliens, Denizens and Citizens in a World of International Migration (Aldershot: Averbury, 1990) and Yasemin Nuhoglu Soysal, Limits of Citizenship: Migrants and PostNational Membership in Europe (Chicago: U of Chicago P, 1994).

7 The arguments here about post-national trends owe much to Yasemin Soysal’s use and discussion of the term as laid out in her book Limits of Citizenship.

8 See T.H. Marshall, "Citizenship and Social Class," in his book Class, Citizenship, and Social Development (Westport: Greenwood Press, 1953) 74-90.

9 See, for example, Rainer Bauböck, "Cultural Minority Rights for Immigrants" (unpublished paper 1995).

10 Michael Mann, "Ruling Class Strategies and Citizenship," Sociology 21 (1987): 339-54.

11 Mann 339-41.

12 Bryan S. Turner, "Outline of a Theory of Citizenship," Sociology 24.2 (May 1990): 189-217.

13 Marshall, Mann, and Turner represent, of course, only one dimension of literature on historical models and understandings of citizenship and citizenship practices, as well as on the changes in these models and practices. For a sampling of recent studies, see Soysal, Limits of Citizenship; Rainer Bauböck, Transnational Citizenship: Membership and Rights in International Migration (Aldershot: Edward Elgar, 1994) and Bauböck, ed., From Aliens to Citizens: Redefining the Status of Immigrants in Europe (Aldershot: Averbury, 1994); Rogers W. Brubaker, ed., Immigration and the Politics of Citizenship in Europe and North America (Lanham: U of America P, 1989); J.M. Barbalet, Citizenship: Rights, Struggle, and Class Inequality (Milton Keynes: Open UP, 1988); and Jürgen Habermas, "Citizenship and National Identity," in Bart Van Steenbergen, ed., The Condition of Citizenship (London: Sage, 1994) 20-35.

14 For diverse perspectives on the linkage of citizenship and immigration, and citizenship and ethnic diversity, see Brubaker, Immigration and Citizenship and Nationhood in France and Germany (Cambridge, MA: Harvard UP, 1992); Bauböck, Transnational Citizenship and From Aliens to Citizens; Gary Jacobsohn and Susan Dunn, eds., Diversity and Citizenship: Rediscovering American Nationhood (Lanham: Rowman and Littlefield, 1995); Yasemin Nuhoglu Soysal, "Changing Citizenship in Europe: Remarks on Postnational Membership in Europe," in David Cesarani and Mary Fullbrook, eds., Citizenship, Nationality, and Migration in Europe (London: Routledge, 1996) 17-29; Miriam Feldblum, "Paradoxes of Ethnic Politics: The Case of Franco-Maghrebis in France," Ethnic and Racial Studies 16.1 (Jan. 1993): 52-74. Of course, studies of republicanist notions of citizenship not primarily grounded in the context of immigrants and diversity would include work in feminist theory on citizenship and work on social movements, democratic theory, and citizenship. The linkage between feminist critiques of citizenship and the contemporary context of immigration and ethnic integration has also been explored; see, for example, Floya Anthias and Nira Yuval-Davis, The Racialized Boundaries: Race, Nation, Gender, Colour, and Class and the Anti-Racist Struggle (London: Routledge, 1992).

15 For a review of recent literature, see, for example, Will Kymlicka and Norman Wayne, "Return of the Citizen: A Survey of Recent Work on Citizenship Theory" Ethics 104 (Jan. 1994) and Douglas B. Klusmeyer, Between Consent and Descent: Conceptions of Democratic Citizenship (Washington, D.C.: Carnegie Endowment for International Peace, 1996).

16 For a critical look at both liberal and republicanist citizenship (not related to immigration), see Iris Young, "Polity and Group Difference: A Critique of Universal Citizenship," in Cass Sunstein, ed., Feminism and Political Theory (Chicago: U of Chicago P, 1990) 117-42. For works on republican citizenship or republican models of citizenship, see, for the French case, Luc Ferry and Alain Renaut, Des Droits de l’homme á l’idee republicaine (Paris: Presses Universitaires de France, 1985); Feldblum; Françoise Lorcerie, "Les Sciences Sociales au Service de l’Identité Nationale," in Denis-Constant Martin, ed., Cartes d’identité. Comment dit-on "nous" en politique? (Paris: Presses de la Foundation Nationale des Sciences Politiques, 1994); and Adrian Favell, Philosophies of Integration: The Theory and Practice of Ethnic Minority Policies in France and Britain (London: MacMillan, forthcoming).

17 For example, Will Kymlicka, Multicultural Citizenship: A Liberal Theory of Minority Rights (Oxford: Oxford UP, 1995); also Bikkhu Parekh, "The Cultural Particularity of Liberal Democracy," Political Studies XI, special issue (1992): 160-75.

18 See Favell for a discussion of the role of ideas and ideological traditions in the policy debates over immigration integration in France and Britain.

19 Federal Ministry of the Interior, Survey of the Policies and Law Concerning Foreigners in the Federal Republic of Germany (July 1993).

20 Hammar; Zig Layton-Henry, The Political Rights of Migrant Workers in Western Europe (London: Sage Publications, 1990); also see Soysal, Limits of Citizenship.

21 Soysal, Limits of Citizenship.

22 Stephen Castles, "Democracy and Multicultural Citizenship: Australian Debates and their Relevance for Western Europe," in Rainer Bauböck, ed., From Aliens to Citizens: Redefining the Status of Immigrants in Europe (Aldershot: Averbury, 1994) 7.

23 An episode that highlights such strategies were the recent local elections in Berlin, where Turkish immigrants called for, at once, the right to dual nationality, local suffrage for all nonnationals in Berlin, and suffrage in Turkey for nationals living abroad, in Germany.

24 See Miriam Feldblum, Reconstructing Citizenship: The Politics of Citizenship Reform and Immigration in Contemporary France (Albany: SUNY Press, forthcoming).

25 Lorcerie.

26 For excellent compilations of press reviews of recent immigrant reform efforts and legislation in North America, Europe, and Asia, see the monthly news reports of Migration News. For example, "Swedish Guest Workers and Refugees," and "Immigration: Top Priority in France," Migration News 2.12 (Dec. 1995); "Reducing Immigration in Britain and Italy," Migration News 3.1 (Jan. 1996).

27 See, for example, James Blitz, "Asylum Benefit Law will Starve People out of Britain," Financial Times 19 Dec. 1995; Charlotte Eager, "Exiles Dream of Freedom Turns to Dust," Observer 17 Dec. 1995; "Bonn Concern at Asylum Seekers," Financial Times 11 Jan. 1996; Ying Hui Tan "Asylum Seekers Can Only Make One Claim," Independent 24 Dec. 1996.

28 The decrease has been visible for the past few years since the height of the asylum requests in 1992. For example, in 1992, there were 674,000 requests, with the overwhelming number in Germany, while in 1994, there were approximately 305,000 requests. It should be noted, however, that these numbers do not take into account the fluctuations in estimates concerning illegal or undocumented migration. See "Immigration: Fewer Requests for Asylum in the EU," European Report 6 Feb. 1996; "EU: Number of asylum seekers down in most member states," Agence Europe 3 Feb. 1996.

29 Bryan S. Turner, "Postmodern Culture/Modern Citizens" in Bart Van Steenbergen, ed., The Condition of Citizenship (London: Sage, 1994) 153-68.

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