This article analyzes American democracy from a European perspective. It argues that American democracy (like European democracies) is based on antinomies, two societal and two institutional, deeply rooted in American constitutional development. Thus, each time American democracy has been used as a model and exported, the attempt has ended in failure. An antinomic model can be studied but not imitated. The article concludes that what is interesting for non-Americans is the way American democracy has historically dealt with these antinomies, more than the American model per se. The American method has to do with a peculiar constitutional structure that, having had the chance to institutionalize liberal principles, has tended to promote a positive-sum solution to those antinomies, in accord with individualistic values. Here resides the great divide between American and European constitutional structures; for opposite reasons, the European constitutional structure tends to promote a zero-sum solution to similar antinomies, in agreement with collectivistic values. In both structures, something important may be lost—private freedom in the latter and public good in the former. Could a reciprocal constitutional learning process allow both sides to learn the missing side of the story?


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  • Article Type: Review Article
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