Outside the Beltway

The Irresponsible Government Model

The Epstein fallout highlights differences in the US and UK systems.

James Joyner · Tuesday, February 10, 2026 · 2 comments

Over the last few days, I’ve come across several pieces noting that the recent Epstein files releases seem to have had much more real consequences in Europe, and particularly in the UK, than they have here in the US. I would have skipped The Atlantic‘s Idrees Kahloon‘s version, with the absurd headline “British Politicians Still Have Shame,” had Taegan Goddard not highlighted this:

There is an irony to the undying Jeffrey Epstein scandal: It may never be more than an annoyance for President Trump, who knew Epstein well, but it could topple British Prime Minister Keir Starmer, who never met the sex-offender financier. Starmer has a 71 percent disapproval rating and leads the least popular British government since World War II. The reasons for the Labour Party leader’s deepening plight are moral, because decency and shame still matter in British politics. But they are also institutional. An American president is less democratically accountable than the British prime minister, because partisanship has disabled the checks that the Founders placed on the chief executive.

I dismiss out of hand the notion that the Brits care more about “decency” than we do. American politicians have their careers ruined by sex scandals that are much less shocking than Epstein’s all the time. So, no, shame is not the key variable.

Kahloon’s point about institutional dynamics, on the other hand, is spot on.

You would think that the British prime minister—who definitionally has a parliamentary majority behind him in a country in which Parliament is supreme—would be able to behave more like an elected monarch than the American president, who is supposed to be constrained by checks and balances. In the modern day, the opposite looks to be true. Parliamentary systems encourage palace coups because if you remove your party’s leader, you might be able to claim the job. If you successfully impeach and remove the American president, though, you don’t get to succeed him. The ever-present possibility of a no-confidence motion is supposed to keep a prime minister democratically accountable; impeachment is designed to be used in extreme cases. But its repeated use in recent decades—once against Bill Clinton, and twice against Trump—has proved its futility as a meaningful check on the president. In a time of closely divided and extremely partisan Congresses, the chance of a successful conviction in the Senate is close to zero—even if the president does something like try to stay in office after losing an election.

I’m not sure that three impeachment attempts over the span of decades constitute overuse. But, yes, we have seen that it is next to impossible to get a significant number of Senators from the President’s party to vote to remove him from office.* Indeed, none did in the Andrew Johnson or Bill Clinton impeachments.

Nor do I think the prospect of a “palace coup” explains why it’s easier to oust a British premier. Rather, it’s because the Westminster system is one of party government. While the party leader is certainly the face of the (very short) UK election campaign, citizens are voting for Labour, Conservative, Liberal, Reform, and other party platforms. Shedding a PM embroiled in a scandal—or simply one with sagging poll numbers—can be good for the party.

When Margaret Thatcher became unpopular after almost 12 years in office, pushing her aside for John Major would extend Tory governance for another six years. Ousting Tony Blair (10 years) for Gordon Brown gave Labor almost three more years. More recently, the Conservatives held on to power by David Cameron (6 years) handing off to Theresa May (3 years), Boris Johnson (3 years), Liz Truss (50 days!), and finally Rishi Sunak (just under 2 years). Indeed, in every instance except the Blair-Brown switch, the party won another mandate.

By contrast, American Presidents spend years campaigning for their party nomination and then months running against the other party’s nominee for the White House. Removing one is therefore much more drastic, as it effectively overturns an election.**

Kahloon is also correct to note that our system does not work as advertised.

Congress has, over the past half century, also turned over more and more of its authority to the personal discretion of the president and the executive branch. When Thomas Jefferson was writing on the demerits of parliamentary government, he observed that “an elective despotism was not the government we fought for; but one which should not only be founded on free principles, but in which the powers of government should be so divided and balanced among several bodies of magistracy, as that no one could transcend their legal limits.” When there is no separation of powers, but merely a separation of parties, this intricate system breaks down, leaving an imperial presidency with exactly the concentrated power that the Founders feared.

The irony is that the UK model has the opposite of separation of powers: a fusion of powers. While we call it a parliamentary system, it’s really a cabinet model in which the PM and senior party leaders govern, with the rest of the party’s parliamentary membership acting as a rubber stamp. So long, that is, as the government retains the confidence of said membership.

In the vision Hamilton, Madison, and Jay sold us in the Federalist, the US system is quite different. The President is independently elected and represents the interests of the nation as a whole; Senators represent the interests of their states; and Representatives represent those of their local districts. And, to some extent, that remained true well into my memory of the system’s functioning. As the parties have sorted geographically and ideologically, though, they are much more nationalized and cohesive. Republican Members, especially, see their fortunes tied to Trump.

The British model is often called “responsible government” because it allows much greater accountability. Not only can parliament hold ministers to task, up to and including removing them from office, but the public knows which party to hold responsible in the next election. Historically, that has been a challenge in our diffuse system, because Presidents can blame Congress — and often the opposition party in Congress — for failures. More recently, though, even local elections have become referenda on presidential performance.

Kahloon is also right here:

They might also be saddened that 250 years after declaring independence from a tyrannical British king, the American system of government has arguably less democratic accountability for its leaders than the British one. But perhaps they would not be entirely shocked: The idea that there was something intrinsic to America that immunized it from autocracy was anticipated and deemed not credible. “Human nature is the same on every side of the Atlantic,” Jefferson wrote, adding, “The time to guard against corruption and tyranny, is before they shall have gotten hold on us.”

There’s simply no doubt that the current British system is more democratically representative than ours. Indeed, while Steven Taylor and I are very much on the same side on the “We’re a Republic, not a democracy” argument, ours was inherently undemocratic in design. Even aside from the fact that Senators weren’t chosen directly by the people until the 17th Amendment (1913) and Presidents are still elected by the indirect Electoral College, the disproportionate weighting of the Senate (and thus Electoral College) means some citizens’ votes matter considerably more than others.*** And don’t even get me started on the filibuster, blue slips, and other undemocratic mechanisms in the Senate.

Still, it was supposed to represent local and institutional interests and prevent the concentration of power. The Framers could not have envisioned anything like the national security state that arose with World War II and then the Cold War. Or the nationalized information environment created by radio and amplified by television and the Internet. The Presidency has gotten steadily more powerful and Congress less able and interested in checking that power. And Trump has shown the degree to which what little constraint remained was mostly a function of his predecessors feeling bound by norms.

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*It’s also worth pointing out that there were arguments that the infractions in the Clinton and first Trump impeachment actually didn’t warrant removal from office. And, by the time the third Trump impeachment happened, he was a week from being out of office, so voting against removal was easier to rationalize.

**We saw this pretty clearly in 2024, when Joe Biden merely effectively handed the Democratic nomination to his Vice President. While Kamala Harris was duly elected to that office, few people actually base their vote on the bottom of the ticket. Those who had voted for Biden in the primary rightly felt that they had been disenfranchised, even though they technically voted for Harris as his replacement.

***And, of course, the original design embraced slavery and denied the vote to everyone but White men over 21.