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Based on a wide range of historical variations, citizenship can be ultimately reduced to two core meanings which apply to all historical phases that the formation of citizenship as subject and concept has undergone. Citizenship can be understood to mean, first, membership in a political community and, secondly, a form of active behavior toward the community which constitutes the good and responsible citizen. First, as a membership status, citizenship can be – but need not be – based on a common set and belief of belonging which gives a common ground and internal stability to the community. It always confers, however, the status of equality among all citizens with respect to the rights and duties that the status implies. Second, citizenship in the meaning of good civic behavior has its origins in the model of the ancient Greek city-state citizenship. It was ideally and practically linked to democracy by the civic virtues of an active “citizen,” which permitted him to “share in the polis.” In this meaning, citizenship is linked both to the political and the collective identity paradigm of citizenship. The obligation of active engagement in the polity and the more passive commitment to commonly shared values and convictions are interpreted as an essential prerequisite both of citizenship and of civil society. Since, as a principle of political order, citizenship refers both to the state as well as to society, it represents a crucial precondition for the existence of civil society and fundamentally shapes its practice.
The eighteenth century brought a political breakthrough for the concept of citizenship. Since then, citizenship has become a fundamental category of thinking in social science and political debate. Indeed, citizenship has become one of the most influential concepts after World War II. It is used by sociologists and anthropologists, legal experts, as well as historians. The topic of citizenship is linked to a broad variety of issues. Citizenship and citizenship rights are a major theme in debates over the development of the welfare state. They also serve as political concepts for the mobilization and participation of citizens. Citizenship is a central legal institution to ascribe voting rights and the duty of conscription. In political as well as scientific debates on migration, national identity, and its limits all over the world, the idea of citizenship has come to play an increasingly important role. In attempts for transnational and supranational community building, the institution of citizenship, in particular European citizenship, is an increasingly important issue both in politics and scientific literature. In general, the fundamental theoretical categories for the analysis of any society or community, inclusion and exclusion, are perfectly well exemplified by the institutional structure and practical working of citizenship.
The political and practical relevance of citizenship thus goes far beyond the scientific context. It is deeply rooted in the history of the concept. Like many political concepts, citizenship has developed from a political claim to a concept of legitimation. From its very beginning, it has been closely linked to individual claims for autonomy, for the recognition of individual rights, as well as for equality against status differences. The use of the concept of citizenship ranges from the particular national level to a universal global meaning.
The historical origin of citizenship is European. The Greeks were the first society to combine the legal provisions of membership with a political theory of membership virtues and institutions in order to perpetuate their idea of citizenship. The legal status of citizenship established equality among Athenian citizens in terms of their rights and obligations. The status of equal membership marked privilege vis-à-vis nonmembers. Apart from the legal framework, the concept of Athenian citizenship included a set of citizen values, behaviors, and communal attitudes.
Roman citizenship – more complex, expansive, and legalistic than its Greek counterpart – revealed the development of citizenship from an instrument for defining the city-state community to one for the legal integration of an extensive world empire.
With the loss of a central, universal legal structure at the end of the Roman Empire, citizenship became obsolete as a political concept. Christianity rejected the model of political order to which ancient philosophy, especially Aristotle and Cicero, had contributed. It developed a complete and alternative system of social and moral values that helped establish a new institutional political order. A system of multifaceted loyalty replaced the citizen’s concentrated loyalty to the state.
The lack of a centralizing and nationalizing state power in parts of medieval Europe left room for the growth of a strong, urban citizenship, particularly in the city-states of Northern and Central Italy (Heater 1990, p. 23). The theory and political order of state sovereignty in European absolutism, with its concentration of central state power and its unambiguous claim to loyalty, prepared the ground for a national rather than local concept of modern citizenship. The personal and territorial delimitation of sovereign states and the ordering of their international relations increased the necessity to define membership in and allegiance to the state. The call for individual rights of religious freedom and self-government, strengthened by religious opponents of the state, and revolutionary efforts to found governments upon popular sovereignty, for example, in England, were the predecessors to active citizenship.
The eighteenth century brought a breakthrough in the defining of citizenship, with political theory and institutions at its core. In the American and French Revolutions, the word “citizen” – and its French equivalent, citoyen – became a key concept in the legitimation of the political struggle against the feudal ancien régime, as well as in the struggle for equality before the law, freedom from religious discrimination and arbitrary arrest, the extension of political rights, and popular democracy. From this point onward, citizen, citizenship, and citoyenneté became core terms of a state order based on democracy and constitutionalism.
The key concept of citizenship (citoyenneté) in the French Revolution combined four traits that were to become essential for the development of citizenship throughout the nineteenth and twentieth centuries: an egalitarian, anti-feudal impetus; confirmation as a key concept of the legal constitution; an association with extensive individual rights; and, finally, nationalization. The modern concept of citizenship arose together with the concept of the nation-state and became one of its central legal institutions. The age of revolution and constitutionalism in the Western world was also an age of an increasing delimitation of national citizenries. Extended citizenship law came to define membership in the nation-state as well as the rules of naturalization policies. Citizenship and citizenship law (in the sense of nationality law to define formal membership in a nation-state) became key instruments for defining national identity (Gosewinkel 2003) and controlling migration in a modern world characterized by increasing transnational mobility (Brubaker 1992).
The central function of citizenship in defining membership in the sense of nationality was supplemented by a second main function, i.e., conferring upon the citizen individual rights vis-à-vis the state. In the nineteenth and early twentieth century, Western constitutional states extended the range of civil, political, and, increasingly, social rights that were reserved mainly for their own citizens. The nationalization of citizenship as a membership status corresponded to a nationalization of citizens’ rights. Citizenship became an institution for distributing “life opportunities” in a world of nation-states.
As the importance of citizenship as a legal entitlement increased, its extension to new members became more and more contested within the national citizenry. The struggle for inclusion, in European as well as in American constitutional law, dominates the history of citizenship to this day. The gradual extension of equal civil rights to groups resident on the nation-state’s soil who had been denied citizenship rights and were subjected to discrimination on the basis of ethnic or national origin, religious beliefs, social status, or gender determined the direction that citizenship was to take. The claims of discriminated groups to equality became the motor for full inclusion in the community defined by citizenship.
With the decline of liberal democracy, the rise of radical nationalism, racism, and totalitarian dictatorship in the constitutional states of Europe and Asia, the period between the two world wars represented an interruption in the development of modern citizenship in its meaning as individual citizenship. The dominance of ascriptive national, ethnic, or racial criteria in admission to citizenship, the splintering of the citizenry through hierarchical classes of rights, the withdrawal of civil rights, and massive expatriation of millions destroyed the core of equality within the concept of citizenship. The fact that countless people during that period became stateless and were hence deprived of rights and protection revealed how dependent citizenship was on the liberal legal structures of the nation-state (Gosewinkel 2016).
In sum, the historical development of citizenship from its beginning until the second half of the twentieth century has been characterized by a multiple process of expansion. It expanded from a membership status in a local community to a central membership in the territorial nation-state. Citizenship as entitlement to individual rights was transferred from the level of the nation-state to that of supranational communities. From its inception in the Greek city-communities, the concept and ideal of citizenship has spread beyond Europe all over the world to states based on the principle of constitutional democracy. The substantive program of citizenship as a set of individual rights has expanded from political and civil to encompass social and economic rights and, ultimately, cultural and environmental rights as well. Developments in the second half of the twentieth century in all of Europe and beyond saw, on the one hand, the restoration of liberal democracy in Western Europe after World War II and a reconstruction of citizenship. This was reinforced and extended to the global arena with the end of ideological-block confrontations after 1989 and the adoption of democratic and constitutional patterns by most of the formerly communist states.
While the relevance of citizenship as an institution of modern society as well as an instrument of social analysis is commonly recognized, its conceptualization is under debate. This is mainly due to the increasing practical importance of citizenship as a membership status until the second half of the twentieth century, as a set of rights and obligations as well as a standard of legitimizing – particular – feelings of identity and modes of civic action. To the degree that citizenship became an institution of inclusion into the (welfare) state or national citizenry and an instrument of struggles for recognition (Fraser and Honneth 2003), the academic debate over its function, reach, and limits assumed an increasingly political impact.
Conceptualization Under Debate
In his 1950 work named Citizenship and Social Class, Thomas Marshall famously analyzed citizenship as a set of rights according to three main categories: civil, political, and social rights (Marshall 1950/1992, p. 8). Marshall’s evolutionary interpretation of citizenship became the point of departure for the theory and definition of citizenship after World War II. His concept of citizenship, developed implicitly on the model of the institution’s development in England in the immediate post-World War II period and in the heyday of the Western welfare state, however, has since met with criticism from various perspectives. The most important lines of criticism particularly focus on historical, social, and territorial “frontiers” (Vogel and Moran 1991, p. xii).
Marshall’s analysis of the development of citizenship as a sequence of civil, political, and social rights is deeply rooted in the social and economic history of England as the starting point and pattern of worldwide industrialization. Its Anglocentric orientation differs sharply from the generalized, sometimes even universalistic language of the analysis not only in Marshall’s account but even more in its wide reception by social science. Marshall’s abstract language of “the universal status of citizenship” in its connection with “basic human inequality” (Marshall 1950/1992, p. 6, 44) invites generalization despite the temporal and geographical contingency of its context. There is a wide range of critique. First, predominantly agricultural or culturally different societies – in Europe or beyond – which were not marked by centralized industrial modernization like England did not offer the same structural opportunities for the development of the idea and practice of individualism, equality, and rights. Second, Marshall’s analysis, with its inherent idea of expanding rights, is linked to the Western welfare state in the heyday of its development after World War II. It loses explanatory force in times of decline of public welfare institutions and state power in general due to processes of liberalization and deregulation in Western industrial societies since the 1970s. Third, the Marshallian model of a sequential development of civil, political, and social rights does not fit into every Western or even Western European state. In Germany, for example, the development of a system of social insurance rights at the end of the nineteenth century became a widely accepted model in the industrial world. It preceded, however, the implementation of equal political rights which could not be established durably before the end of World War II. In France, moreover, civil and social rights for women were recognized far earlier in the course of the first half of the twentieth century than political rights which were implemented only after World War II. Fourth, the focus on social, particularly on class struggles, to explain the inherent force of citizenship development faces objections of two kinds. On the one hand, the concept of “social” in Marshall’s analysis is criticized as being far too narrow. Gender, for example, as a social category and an argument for hierarchical discrimination and withholding rights, was not only a contingent aspect but a fundamental structure of modern citizenship from its very beginning (Vogel 1991, pp. 58–85; Siim 2000, p. 13). On the other hand, the particular focus on social struggles to explain the upsurge and persisting relevance of citizenship is criticized and enlarged by a broader conception of struggles for recognition which end up with the codification of rights. The recognition of cultural difference (Fraser and Honneth 2003) as an argument for the implementation of rights paves the way for a new category of cultural rights which are based on claims for cultural identity. These claims may be oriented toward the recognition of individual rights, e.g., sexual rights, as well as collective rights, e.g., ethnic group rights (Isin and Wood 1999).
What these lines of critique have in common is that they do not want to give up the Marshallian model, but they want to modify and adapt it to new contexts in order to enlarge it and to include even more types of rights.
Citizenship as a membership status refers to a personal relationship between an individual (or a group) and an institution. From its origin, however, this relationship always included a territorial aspect. Citizenship as a status of full membership could only be realized within the territorial frame of a state, nation-state, city, etc. In the age of the nation-state, the interrelation between the territorial reach of (nation-)state power and the status of membership became particularly close. The nationalization of citizenship meant that the right to hold and exercise most of the rights of a citizen was derived from birth or stay in the territory of a nation-state. Increasingly, systematic controls of the territorial boundaries of nation-states regulated the right to residence as a precondition for naturalization and citizenship. Citizenship as a status of nationality became the precondition for most of the elementary rights conferred or protected by the state. The line between inclusion and exclusion was sharply drawn by the status of citizenship within a territory. This model of inclusion and exclusion underlies the Marshallian model of citizenship without being mentioned explicitly.
This is criticized by literature which demonstrates another – territorial – “frontier of citizenship” (Vogel and Moran 1991, p. xiii). Its point of departure is the change and partial decline of the territorial bindings of citizenship. One basic reason is the eminent upsurge of cross-national migration after World War II due to fundamental political and economic changes: the postwar economic boom, decolonization, the opening of the communist systems in Europe and Asia, as well as an unprecedented phase of globalization in world economy. This new quality of mobilizing citizens all over the world to move and work abroad has changed the basic assumptions of national citizenship regimes (Castles and Davidson 2000). The discrepancy between the place of birth and the place of permanent residence, increasing intermarriage and a growing need for the social integration of long-term residents with foreign citizenship, led to changes in the legal regulation of membership. The national regulation of citizenship and nationality, encouraged by new developments in international law, is now gradually admitting multiple nationalities. Citizenship regulations are negotiated between nation-states in bilateral or multilateral agreements. Territorial residence and personhood – instead of ethnic descent – more and more legitimize the exercise of individual rights which had hitherto been reserved to members of the nation-state (Soysal 1994).
The denationalization of citizenship can also lead to alternative forms of territorialization. This becomes evident in supranational institutions like the European Union (EU). EU law is developing a particular kind of supranational membership status, “European citizenship” (Bauböck 2019). This nascent form of supranational citizenship that, according to EU primary law, “shall be additional to and not replace national citizenship” (Art. 20 TFEU) was designed to confer specific “European” rights upon citizens from EU countries. Apart from this form of supranational citizenship, which has emphatically been conceptualized as the “fundamental status of nationals of the member states” by the Court of Justice of the EU, there is a wide range of specific rights and entitlements particularly in the social and economic domain recognized by EU jurisdiction. These rights are detached from national citizenship and the territory of the nation-state (Weiler 1999). They are, however, connected to a new territoriality: the European Union.
Citizenship and Civil Society
Citizenship and civil society can be interpreted as interdependent. The degree of interrelatedness depends on the concept of civil society: civil society can either be conceptualized as a specific quality of “civil” interaction (Gosewinkel and Rucht 2003, p. 49) or as an intermediary sphere of action between the state, the economy, and the private sphere where associations organize and act publicly and in self-determination. If one follows an “associational” concept of civil society (Walzer 1995, p. 153), a common ground of civil society and citizenship consists in a specific legal framework. Both the exercise of citizenship rights and the activities of civil society actors are based on the codification and judicial enforcement of individual rights, particularly civil and political rights, e.g., the freedom of speech and association and the right to vote. Historically, this junction goes back to the Age of Enlightenment. The renaissance of civil society theory during the second half of the eighteenth century was closely linked to the idea of natural law and often resulted in the claim for individual, constitutional rights. Theoretically, the link between citizenship and civil society can be conceptualized in the following ways: first, citizenship as a political institution serves as an “interface” between the organization and the individual relating state and civil society, government, and the people (Giesen and Eder 2001, p. 4; Janoski 1999, p. 12). Second, citizenship rights are an instrument of participation in the public sphere as the genuine sphere of civil society (Cohen and Arato 1992). Thus, changes in the concept and practice of citizenship rights, e.g., the shift from national to transnational rights, contribute to the redefinition of the sphere of civil society (Soysal 2001, p. 160, 172). Third, according to a communitarian perspective, civil society as an associational network serves as a school for the values and virtues of a good (democratic) citizen. While this perspective is disputed by liberal theory (Kymlicka and Norman 1995, p. 294, 296), there is consensus about the interrelation of the two concepts: civil society has come to need citizenship as the codification and practice of rights and values; in turn, citizenship presupposes civil society as a space for organizing and practicing individual and diverse concepts of freedom.
At the beginning of the twenty-first century, there is a dual and somewhat paradoxical tendency in the development of citizenship. On the one hand, there is evidence of a trend toward some “devaluation” and weakening of citizenship. (Fahrmeir 2007) The weakening of nation-state structures, the trend toward transnational political unions, global standards, and guarantees of civil rights as human rights have all diminished the importance of (national) citizenship for the conferral of individual rights (Shachar 2009). While formal citizenship is still crucial on the level of the right to full participation in the political arena, this no longer applies to economic and social rights. Citizenship as national membership status is of decreasing importance for the exercise of these increasingly relevant rights (Soysal 1994, p. 136).
On the other hand, the apparent trend toward the devaluation of citizenship that began in the second half of the twentieth century is joined, first, by the expansion and possibly overstretching of the concept. Historically, citizenship’s large efficacy as a claim for rights was always based on political sovereignty – be it monarchical or popular. This was a prerequisite both for addressing individual claims and enforcing the corresponding civil duties. With the pluralist expansion of citizenship rights to new kinds of conflict-ridden, often controversial claims for identity in a situation of declining nation-state sovereignty, the answer to the question “Who guarantees and enforces claims for citizenship?” becomes less clear. Secondly, recent trends toward a renaissance of a stronger demarcation of nation-states and the reinforcement of national citizenship rights in Europe and beyond point to the renationalization of its membership status. Citizenship seems to have lost some of its importance as a membership status. Its replacement, however, by universalist or supranational guarantees of rights no longer appears as a “realistic” vision in the near future.
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