Leif Kalev, Henry Sinivee Tallinn University Institute of Political Science and Governance

Transcription

1 Multiple Citizenship: Rhetoric and Regime Change Leif Kalev, Henry Sinivee Tallinn University Institute of Political Science and Governance 1. Introduction Multiple citizenship, this is holding simultaneously the citizenships of many states, has become a persistent topic for public and scolarly discussion. While in most of 20th century the dominant rationale was reducing multiple citizenship the developments after the Cold War have resulted in what several authors see as the trend towards toleration of multiple citizenship (see e.g. Howard 2005, Sejersen 2008, Joppke 2010, Kivisto, Faist 2010, Dumbrava 2014). On a closer look this change includes several trajectories with different aims, measures and impact, but also a counter trend of limiting multiple citizenship. This could be related to the impact of 9/11/2001 attacks or other processes of transnational conflict, terrorism and war characterising the recent decades of the world. Is securitising (see e.g. Nyers 2009, Guillaume, Huysmans 2013) the key rationale for the countertrend and what is its relationship to liberal globalisationism is one of the aspects we study in this article. Citizenship regimes neither operate nor are changed in vacuum. Studying the underlying factors is challenging as they could be very diverse. In any case it could be expected that changes have background considerations that at least in their most crucial aspects should be reflected in media. Thus our key focus is on the media debates on multiple citizenship: what is their scope and intensity, how do they relate to legislative changes etc. However modest, the media coverage or public rhetoric should give us an understanding what is timely and communicated as relevant or persuading. This article focuses on the current dynamics of multiple citizenship regimes and debates in the Central and Eastern European states that have also become new members of European Union. Here we find both the experiences of post communism, rebuilding nation states and Europeanisation that are diversified by socio-cultural backgrounds. Thus we expect it to be an interesting case for analysing competing rationales of multiple citizenship. We examine the change of multiple citizenship regimes of Estonia, Latvia, Lithuania, Slovakia and Croatia in recent decades. In addition to changes in legal regulation we focus on the debates on multiple citizenship in media that should reflect substantive background considerations. 1 The analysis is conducted in three layers: (1) regimes and regime change, (2) debates on multiple citizenship, and (3) substantive dimensions of citizenship in the debates. 1 Changes in multiple citizenship regulation are the well visible aspect of various political processes and debates. In a democratic polity public debate on policy preferences is expected and thus we can analyse to which extent the media coverage and regulation change are related. We can also expect the debate to be based on arguments that address the topic in a rationalisable manner be it more deliberation-oriented (e.g. Habermas) or resultoriented (e.g. Hood 1998: ). Whereas mediatisation (see e.g. Papadopoulos 2013: 47-78) could make news coverage more occasional and limit the explanatory scope of our study we expect the most important debates pass through the veil of commercialisation and simplification. 1

2 On a general level multiple citizenship is a relatively straightforward issue of public policy. Regime and its change are visible in legal regulation and arguments in favour and against are visible in the debates. The scholarly research usually also focuses on the regime change and possibly the related debates. Studying legal regimes and regime changes provides us an understanding whether multiple citizenship is an issue for practical governance. This layer of analysis is rather limited and mostly serves as the basic context for the two subsequent layers. Analysing the direct debate on multiple citizenship informs us about the scope, orientation, arguments and participants of the public discussion. Examining the substantive dimensions of citizenship in the debates provides us knowledge which layers and aspects of meaning of citizenship are articulated in the debate, how are they related to permissive and restrictive positions on multiple citizenship and to the broader conceptualisation of citizenship. The debates on multiple citizenship inform us on much more than just the range of the rights of citizens and the capacity of states to manage diversity that are usually studied. They also touch the deeper layers of citizenship and thus the issues of the citizen status and agency, the basis for self organisation of political communities, democracy and popular sovereignty, to name but some (see e.g. Brubaker 1992, Sorensen 2004, Blatter 2011, Beckman, Erman 2012). Studying multpile citizenship debates also provides us understanding on what is seen as relevant for political communities and their members in this time and place. The general approach of the article has been outlined in introduction. Subsequently we will outline the theoretical frames and methods of the study. This is followed by the results of empirical analysis, discussion and conclusions. 2. Theoretical framework and methodology 2.1. Citizenship as regime and concept Citizenship is a contested and multi-used but also heuristically rich concept. Very broadly it characterises the agency of a person but this can be defined in legal or societal terms, towards the state or fellow citizens (also termed vertical or horizontal), encompassing status, participation and identity, covering political but also civil, social, cultural, economic and other domains and there is plenty other aspects and approaches available (see e.g. Jakobson 2014 for an overview). Citizenship is also a regime, a set of legal rules stipulating membership(s) of a (nation) state, often termed nationality. These rules encompass acquisition and loss of the status, rights and obligations arising from it and other aspects deemed relevant to legislate. Besides nation state level some aspects of citizenship can also be legislated on an international or supranational level (e.g. statelessness and European Union citizenship respectively) but the key locus of citizenship regimes is clearly the nation state (see e.g. Dumbrava 2014 for an overview). Citizenship as a concept and citizenship as a regime are related but not the same. As a concept, citizensip is broad and manifold. As a regime, it is legal and concrete. Citizenship as a concept informs the deliberations about citizenship regimes and thus acts as a potential agent of change. Citizenship as a regime provides practical anchoring influencing the development of citizenship as a concept. Whereas citizenship as a regime is visible from legal regulations and their comments, citizenship as a concept is besides theory manifested in 2

3 public debates and deliberations about citizenship, usually in the context of the current citizenship regime. In this article, we understand citizenship regime as clearly based on legal rules (see e.g. Vink, Bauböck 2013) diverging from some authors applying a broader definition (e.g. Humphrey 1999: 25, Shaw and Štiks 2010: 6). Citizenship regime is the framework upon which the relationship between governance institutions and citizens is built (Dalseg 2012: 3) and is useful in order to capture the historically contingent differences in practising citizenship (Jenson 2005: 5). Citizenship regime can be defined as the institutional arrangements, rules and understandings that guide and shape policy decisions and expenditures of states (Jenson, Papillon 2000: 246). Citizenship regime has 4 dimensions: It establishes the boundaries of inclusion and exclusion of a political community (Jenson and Papillon 2000:246). It s done through recognition of particular rights and duties (civil, political, social, and cultural; individual and collective) (Jenson 2005:6). It prescribes the democratic rules of the game for a polity (Jenson and Papillon 2000:246). It also prescribes the governance arrangements of a polity, which include the institutional mechanisms giving access to the state, the modes of participation in civic life and public debates and the legitimacy of types of claims-making (Jenson 2005:6). It contributes to the definition of nation in the narrow passport-holding nationality and the more complicated national identity (Jenson and Papillon 2000:246). It contributes to the definition of membership and the borders of insiders and outsiders (Jenson 2005:6). It sets the geographical borders of the political community, giving meaning to the frontiers between states (Jenson and Papillon 2000:246). It involves the expression of basic values about the responsibility mix, defining the boundaries of state responsibilities and differentiating them from those of markets, of families and of communities in the welfare diamond (Jenson 2005:5). Citizenship regime also includes positions on dual or multiple citizenship that could be termed multiple citizenhip regime and are the focus of this article. Whereas the negative position is usually expressed in a short and straightforward manner the toleration of multiple citizenship can vary in scope and be subject to several conditions, limitations and other specific rules, some of which could be only indirectly related to the issue. Following the approach adopted in the article we expect multiple citizenship regime be understandable primarily on the basis of national constitutions and citizenship laws. As already marked, citizenship as a concept is diverse and manifold. We focus on many but not all of the dimensions and aspects of citizenship to develop the analytical framework for our empirical study. First we discuss some of the key tensions in the concept of (formal) citizenship and summarize the arguments to study the direct debate on multiple citizenship. Second, we outline the widespread substantive divisions in theorising citizenship and develop these to a framework for analysing their manifestation in the debate on multiple citizenship. Citizenship is a concept synthesised of various elements and having internal tensions. These could be understood as aporias, insolvable impasses stemming from equally valid but inconsistent principles or premises. These include community-autonomy and rights-privileges axes (Huysmans, Guillaume 2013). The aporias become amplified in the case of dual or 3

4 multiple citizenship, usually defined as the status of citizen of two or more states simultaneously (see e.g. Hansen, Weil 2002; Martin, Hailbronner 2003, Sejersen 2008). People need to exist as parts of common will a polity or an imagined political community while at the same time they also need to remain autonomous, forming a plurality of wills with various opinions, interests, and values and negotiate their living together. (Balibar 2002: 181 cf. Huysmans, Guillaume 2013) Political authorities seek to constitute unity by claiming to represent the community and its interests as a whole. Their claims are necessarily hypocritical, because democratic political rulers cannot fully transcend the community of autonomous people, who as subjects hold different opinions and values, since they derive their legitimacy from mobilising support from within a plurality (Latour 2003 cf. Huysmans, Guillaume 2013). Citizenship has also been an instrument both of crafting a people of equals, in which rights are universal and not a privilege, as well as dividing people into territorialised national polities turning universal rights and belonging into privileges of membership in a polity. (Huysmans, Guillaume 2013). On the one hand, citizens comprise a people united around a body of law and rights and/or a set of narratives about its origins that allow people to recognise themselves as a collective unity and a body of individuals with political status. On the other hand, citizenship is constituted in relation to those with limited or no rights, those remaining outside of the narratives of the people s community of origin (Isin 2002). These tensions are even more visible in case of national legal regimes of multiple citizenship (e.g. Bauböck 1994, Vink, Bauböck 2013, Dumbrava 2014) where the equality of members of a polity (whose rights are simultaneously privileges differentiating them from other polities) becomes further complicated by multiple memberships. The different rationales for political community and individual status are also well visible. Fom the perspective of state institutions there can be a difference between expansionist outgoing (diaspora) and reductionist incoming (immigrant) multiple citizenship. And whereas individual opportunities can be enhanced by holding multiple citizenships it creates new kinds of inequalities between citizens and it is also demanding to use multiple rights and meet multiple obligations fully and simultaneously. In general, the question is about the potency of multiple citizenship to differentiate between compatriots and others and thus act as a meaningful instrument of identity and social organisation. It is clearly debatable to what extent it is possible to be part of multiple polity building projects, exercise one s autonomy, and be simultaneously subjected to multiple rules and authorities Debate on multiple citizenship The scholarly and public discussion on multiple citizenship has various approaches and layers of meaning. Some focus on the context and some on the content (see e.g. Faist 2007, Blatter 2011, Guillaume, Huysmans 2013). Concerning the context the discussions have been related to globalisation and transnationalisation but also securitisation and operation of democratic political communities. Concerning the content there are several dimensions and aspects of citizenship discussed in the relation to multiple citizenship. The post cold war era has been generally characterised as growing toleration of multiple citizenship both in debate and regimes in the general context of globalisation and liberalisation (e.g. Soysal 1994, Martin, Hailbronner 2003, Sejersen 2008). In this context we 4

5 can speak of postnational citizenship, transnationalisation and universalisation of global human rights regime that diminish the significance of (exclusive) nation state based citizenship and foster tolerating multiple citizenship. During the last decade this position has become reassessed as the post 9/11 anti-terrorist measures, new wars and conflicts have balanced liberal globalisationism. The counter trend can be characterised as securitisation (see e.g. Buzan et al 1998, Bigo 2000, Dean 2007, Nyers 2009, Guillaume, Huysmans 2013). Securitisation can refer to rather different meanings: (1) prioritizing the aspect of security in managing issues and policy developments as security problems, (2) framing phenomena and areas of life as fields of security expanding the rationality and sphere of expertise of security proffessionals, (3) governing via creating new emergencies or cultures of fear. This could be summarised as creating new meanings and interpreting areas of life through the lenses of security. Securitisation could occur also in the case also for citizenship where following this logic a sharp distinction can be construed between democratic and securitised citizenship: whether rights (i.a. to hold governments to account) prevail over the demand for obedience from citizens (in the name of protecting them from threats) or vice versa. However, thanks to its aporia, richness and volatility citizenship is also a practice of constant negotiating, configuring and enacting political being in securitizing moments and sites including also liberalisation, not only securitisation, and even more, potential to overcome this simple dichotomy (see Guillaume, Huysmans 2013: 3-8). Also in case of multiple citizenship we could expect both liberalising and securitising developments represented by its expansion or contraction in practical legal regimes and the tone of the public debate. Multiple citizenship has been characterised as a test case for the ambivalent relationship between the growing liberalisation of citizenship law on the one hand, and the increasing securitisation of citizenship, the erosion of popular sovereignty and nationhood for full membership on the other hand (Faist 2007: 2). The aspect of full membership refers to another tension in multiple citizenship. One of the key meanings of citizenship is the equality of political freedom. Those who are affected by political decisions should have a say in how they are made. Such decision making needs political communities with members and most authors expect populus and demos to broadly overlap (see e.g. Faist 2007, Dumbrava 2014). Dual citizenship both blurs the boundaries of political communities and creates inequalities of the rights and obligations of the members. The expansion of rights and global and transnational places of their enactment, however, also indicate some possible more positive relationships between multiple citizenship and (postnational) democracy. The key arguments of the direct debate on multiple citizenship are summarised in table 1 also serving as one frame for the analysis. Arguments in favor of multiple citizenship 1. Multiple loyalties are increasingly widespread, multiple citizenship is a way to recognize the real and perceived strong ties and loyalties. 2. There are more and more people who live in two or more countries and participate Arguments against multiple citizenship 1. Loyalty is indivisible, only an unambiguous link between state and citizen can be of high-quality. 2. The lack of clear ties between state and citizen complicates ensuring democracy and civil rights 5

6 actively in the society. Their activity should 3. Certain citizens will have more rights than be encouraged. other: voting in several places, single taxes 3. The open door policy will foster but double benefits etc. naturalisation and promote integration. 4. The chance to leave if things deteriorate in Problems and conflicts between national the country of residence. communities can be overcome by cooperation and agreements. national culture of the country of residence; 5. Concern that immigrants threaten the 4. Multiple citizenship promotes biased voting, in particular, with large cosmopolitan, transnational values and immigrant community. More conflicts on the loyalties. basis of ethnicity, which affect the unity of 5. The ban of multiple citizenship shows the the country. state s negative attitude towards immigrants, 6. Multiple citizenship slows down and permission facilitates free movement between reduces the integration of immigrants: the countries and promotes a transnational bond with land of origin is maintained, the economy. formation of comprehensive understanding 6. The state gains more power in other about the role of citizen slows down. countries, where a large number of emigrants Shortness of understanding of the value and with multiple citizenship live. These citizens meaning of citizenship. are the promoters of values and ties of the 7. Conflicts of loyalty in high positions and in country of origin in the country of residence. civil service, as well as military obligations, 7. Multiple citizenship is unavoidable as in particular dealing with conscription. some countries allow it. 8. Problems with diplomatic protection, 8. In the case of multiple citizenship there is international civil law (inheritance, taxation one so called effective citizenship, which etc.). allows to solve conflicts in military service, 9. The need to represent the interests of diplomatic protection and legal acts. foreign citizens and to direct its efforts in this 9. Unequality of citizens' rights does not exercise, which will reduce resources to occur if the rights correspond to proportionate protect indigenous citizens duties. 10. Multiple citizenship increases security 10. There is no proof that citizens wih risks both directly and indirectly, foreign multiple citizenship participate more in citizens have too much impact in activities that are a threat to national security, parliamentary elections and in other fields of compared to regular citizens politics, society and economy. Table 1. Key arguments in the debate on multiple citizenship. Source: Kalev, Annus Substantive dimensions of citizenship The substantive dimensions and aspects of citizenship offer an alternative frame for the analysis of the debate. These substantive dimensions can also be used to analyse the time and space specific dominants in the debates on multiple citizenship. Four main perspectives on citizenship serve as the basic framework for analysing substantive divisions and their aspects in this article. The first is legal-substantial axis (see e.g. Bauböck 1994 nominal-substantial division, also closely linked to nationality-citizenship division) where citizenship can be treated either formally (nominal citizenship) or as containing substantive dimesions (substantial citizenship). Here, the key interest is to study to what extent the debates on multiple citizenship focus to formal, legal aspects as could be expected in case of discussing regimes and to which extent the substantial aspects of citizenship are covered. 6

7 A second divide is of vertical and horizontal citizenship (see e.g. Jakobson 2014). Vertical denotes the relations between a citizen and a state. Horizontal citizenship is primarily exercised in civil society and means citizen to citizen relations and identities. The key interest is to examine to what extent is the horizontal aspect represented besides expectedly dominant vertical citizenship. The third axis is between individual and collective citizenship (see e.g. Huysmans, Guillaume 2013). Citizenship can be understood as a characteristic of the citizen as an individual or primarily through the collective perceptions of the political community. As we expect the legal approach to be dominant the individual aspect of citizenship should be the key discussion but the collective aspect should also be visible. A fourth differentiation is between the liberal, republican and communitarian understanding of citizenship (see e.g. Delanty 2000, Blatter 2011) reflecting normative expectations accompanying citizenship. Liberals focus on stipulating formal rights and safeguarding their free use, republicans emphasise political agency and contribution to the operation of political community, communitarians emphasise community cohesion as the living basis for meaningful exercise of citizenship. Here, the key interest is whether citizenship is discussed in terms of rights (basis, range, guarantees etc.), political agency (values, activities, balance of rights and obligations etc.) and/or community cohesion (language, culture, traditions etc.). Our expectation is that all these viewpoints are present in the discussion but communitarian and republican tend to be more linked to negative positions on multiple citizenship. A fifth conceptual division is in interpreting citizenship as primarily nation state based, transnational or global phenomenon (see e.g. Jakobson 2014) based on emphasising the respective dimension of citizenship regimes, practices, identities etc. It is expectable the locus of citizenship in discussions to be nation state and the question is to what extent the postnational forms are represented at all. If the postnational aspects of citizenship are brought out we expect these to have mostly positive connotations to multiple citizenship whereas both positive and negative positions can be related to the nation state based view on citizenship. The sixth division is a classical one of civil-political-social citizenship (Marshall, Bottomore 1992) based on the area of life in focus whether it is civil rights, political agency or socioeconomic and socio-cultural domain of citizenship. Civil rights are the basis for individual freedom, are exercised in civil society and are protected by courts. Political citizenship is exercised in political activities and associations, elections and parties are just some examples. Social citizenship means being part of society both in terms of civility and ethnicity (education and culture) but also being part of welfare of this society (at least basic level is accessible for all). Our expectation is that civil and political domains are better represented while civil citizenship has more positive connotations and political citizenship is better reflected in negative argumentation. The seventh division is viewing citizenship in terms of status, identity and/or participation (see e.g. Andersen, Hoff 2001). Citizenship as status encompasses both rules on membership (acquisition and loss of the status) as well as rights and obligations accompanying it. Citizenship as identity covers issues of personal and public values and self-perceptions. Citizenship as participation focuses on practical membership of a society or political community either being there or actively taking part in societal life. Whereas the aspect of status is the most expected element in multiple citizenship discussions our interest is how all 7

8 these three aspects will emerge in debates and how are they related to positive and negative understandings of citizenship. These dimensions and their elaboration in the case of multiple citizenship can be summarized in the form of the following table serving as the framework for analysing the substantive aspects of citizenship in the media discussions. Approach and dimension 2 Legal Substantial Vertical Horizontal Outline and emphasis Citizenship as nationality, a clearly delimited, formal, full and discrete legal status Citizenship as a wide concept encompassing citizen status, participation and identity and also having a collective (political community) dimension Citizenship as a relation between a citizen and a state Citizenship as a relation between citizens (in civic society) Expected manifestation in debates Basic level for discussion, expected to be ubiquitous across the debates and positions If present analysable through subsequent analytical divisions, no expected dominant position with regard to multiple citizenship Basic level for discussion, expected to be ubiquitous across the debates and positions If present analysable through subsequent analytical divisions, possibly more related to positive attitudes on multiple citizenship Individual Citizenship as an individual attribute Basic level for discussion, expected to be ubiquitous across the debates and positions Collective Liberal Republican Communitarian Citizenship as a characteristic of a collectivity, e.g. a political community The core of citizenship are rights and freedoms and their protection The core of citizenship is political agency and contribution to political community The core of citizenship is social practice contributing to community cohesion If present expected to be more related with cautious attitudes towards multiple citizenship Basic level for discussion, possibly more related to positive attitudes on multiple citizenship Basic level for discussion, possibly giving more leverage to cautious attitudes on multiple citizenship Basic level for discussion, possibly giving more leverage to cautious attitudes on multiple citizenship Nation state The (key) locus of citizenship is nation state Basic level for discussion, expected to be ubiquitous across the debates and positions Transnational Global Civil Citizens could have several connections to many states and across borders Citizenship is a universal and primarily global phenomenon Basic personal rights and freedoms and their protection Expected to be more linked to positive attitudes towards multiple citizenship if present in discussion Expected to be more linked to positive attitudes towards multiple citizenship if present in discussion Expected to be present in discussions and more linked to open approach towards multiple citizenship 2 The subdivisions of a dimension are marked with a similar colour 8

9 Political Political agency: activities and associations Expected to be present in discussions and linked to scepticism towards multiple citizenship Social Being part of society in terms of education, Could be developed in any direction Status Participation Identity culture and standard of living Rules on membership (acquisition and loss of the status), rights and obligations related to it Practical membership of a society or political community either being there or actively taking part in societal life Personal and public values and selfperceptions Table 2. Substantive dimensions of citizenship. Source: authors if present, to be examined Basic level for discussion, expected to be ubiquitous across the debates and positions Possibly more related to republican and communitarian emphases and negative on multiple citizenship Could be developed in any direction if present, to be examined Linking the direct debate on multiple citizenship to substantive dimensions of citizenship can be conceptually and theoretically developed in many ways of which this discussion (summarised in the following table) is just an example so in order to understand the practical usage we need empirical examination. Summarising the above arguments, we expect multiple citizenship to be encouraged by a more formal approach based on liberal premises or emphasising postnational features. Negative positions on multiple citizenship could be strengthened by securitising, stressing national cohesion or by a republican emphasis on civic participation in a democratic political community. Other lines and aspects are expected to be diversly used. Multiple citizenship Possibly encouraged by citizenship as Possibly discouraged by citizenship as Global Securitising Transnational Political Human rights Republican Civil Communitarian Liberal Participation Outgoing (links with own diaspora) Incoming (immigrants and increasing diversity) Table 3. Possibly positive and negative substantive dimensions. Source: authors 2.4. Methods As already indicated we study 5 Central and Eastern Europan states Estonia, Latvia, Lithuania, Slovakia and Croatia that are also European Union members. We analyse the multiple citizenship regime as legal regulation and public discussion as media debate. The time period under examination is , the years since the entry into force of European Convention of Nationality of Council of Europe. 3 We selected a sample of states aiming to find diferent regulations and policy trajectories of multiple citizenship. There has been a change towards toleration in Latvia and towards restriction in Slovakia. In Lithuania there have been ongoing discussion and initiatives towards more openness. Croatia stably tolerates and Estonia prohibits multiple citizenship

10 All the five states share a postcommunist background, rebuilding nation states, Westernisation, building up democracy and market economy, and Europeanisation, both in the context of joining and mebership in European Union and interstate learning. The states became independent , Slovakia Most of the states joined European Union in , Croatia in There are differences concerning i.a. population, culture and history. Estonia, Latvia and Lithuania were inside Soviet Union and have been rather cautios towards it successor state Russia. Estonia and Latvia have a large Russophone, and Slovakia a Hungarian minority while Lithuania and Croatia are more homogenous. There is a large Croatian settlement near but outside its national borders, notably in Bosnia and Herzegovina. Estonia and Latvia enjoy historical relations to Nordic countries, others to Central Europe. We will analyse the material in three steps: (1) citizenship regime on the basis of laws and reports, (2) direct debate on multiple citizenship, and (3) substantive dimensions of citizenship in the debate based on media. We use mostly qualitative but also quantitative approach as discussed below. Qualitative analysis is structured on the basis of the above theoretical frames and mostly deductive; the main lines of argument are inductive. Some quantitative aspects are used to organise and generally characterise the material. The key interest is to establish: (1) whether there is a diversity in legal regimes of multiple citizenship and their dynamics? (2) which is the structure, positions and arguments of the debate on multiple citizenship? (3) how are the substantive dimensions of citizenship present in the debate? Thereafter we discuss the key findings in terms of the content of the debate and the relations of the regime change and the media debate. The multiple citizenship regimes of the states are studied on the basis of documents, primarily constitutions and citizenship laws in their 1997 and 2004 version. In addition, EUDO citizenship reports are used as a background material. Debates on multiple citizenship are analysed on the basis of the English language national media. This acts as a strong filter: we expect the most relevant debates reaching media coverage. This also means rather condensed and thin content which has been a rationale for mostly deductive research strategy and focusing to the key phrases. The media channels, content, scope and availability vary across the states. The time period analysed is We proceed in two steps: first, we search for the main media channels in English in every state using Google. Second, we search for the media content of each channel using phrases dual citizenship, dual nationality, multiple citizenship, multiple nationality. We use both attributive and structural coding. Attributive coding focuses on time and context and is based on individual politicians: their positions, political parties and other characteristics visible in the presentation of empirical results below. Structural coding means searching for the text fragments that address the positions and arguments of politicians on multiple citizenship from the media articles. To an extent we can generally characterise the debate of each country based on the numerical data resulting from coding but the key focus remains qualitative although structured and deductive. 10

11 In analysing the regimes we search for provisions on multiple citizens in the constitutions and citizenship laws of the states in two points of time: 1997 and Thereafter we assess the regime change. As an additional source we use the parts texts of EUDO citizenship reports commenting on the situation of multiple citizenship in the given state; this also serves as an introduction to the media analysis. We compare the regimes focusing on the following features: (1) toleration of multiple citizenship, (2) regime type and dynamics, (3) toleration in case of birthright and naturalised citizens, (4) constitutional regulation if existent, (5) citizenship law regulation of multiple citizenship. The analysis of media content is conducted in two stages. First we study the debate in terms of general characteristics, positive and negative positions and arguments. Second, we examine the substantive dimensions and aspects of citizenship in the debate. As general characteristics we compare the number and publication time range of the articles, the positive and negative positions of multiple citizenship and their division in terms of coalition-opposition, political parties and individual politicians as well as the number and division of arguments in the debate. In analysing the content of the debate we search for the positive and negative arguments as well as the key line of argumentation in the debate of each country. We screen the articles, assess positive and negative positions and collect the key arguments as citations. We also compare the arguments present in media discussion to the theoretically possible arguments (table 1), discussing the results (results in table 7, see also appendix 2). The key line of argumentation is qualitatively assessed and discussed with citations as examples. In analysing the presence of substantive dimensions and aspects of citizenship and their relationship to a positive and negative position we search for the dimensions and aspects (table 2) from the pool of citations formed in analysing the positive and negative arguments. The findings (examples presented in appendix 3) are discussed both countrywise and with general trends. After the presentation of the results of the stages of analysis the main findings are discussed in a following subsection. This includes the links of media content and regime change and the discussion of the articulation of citizenship in the media debate. 3. Empirical study 3.1. Regimes The key features of the legal regimes of multiple citizenship by countries are summarised in the following table and discussed below. Estonia Latvia Lithuania Slovakia Croatia 1. Admissibility of 1997 yes/no no no yes yes multiple citizenship 2014 yes/no yes yes/no no yes 2. Dynamics of citizenship regime = neg. stabile; 2 = pos. stabile; 3 = neg. changes; 4 = pos. changes; 5 = potential changes 11

12 3. Admissibility of Citizens by birth yes/no yes yes/no no yes multiple citizenship (2014) Citizens by naturalisation no yes no no yes/no 4. Constitutional regulation Pos. Pos. Neg. Pos. Pos. 5. Regulation of citizenship law Neg. Pos. Pos. Neg. Pos. Table 4. Characteristics of regimes. Source: authors The overall dynamics of the regime of multiple citizenship is clear in Latvia, Slovakia and Croatia. In Latvia, the negative regulation has become positive, in Slovakia, the positive regulation has become negative and in Croatia, the genereal regulation has remained positive. Estonia did not have, neither in 1997 nor in 2014, an unambiguously fixed position in multiple citizenship topic as the citizenship law prohibits multiple citizenship but owning it is not penalized. In Lithuania in 1997 there was a clear prohibition regime, but as 2014 the legislator wants and has tried to make changes in it. However, there is no definitive revised legislation in force. Both Estonia and Lithuania lack final clarity in the multiple citizenship topic. One can also divide countries by the dynamics of the regime. Because there has not been any changes in Estonian regime between 1997 and 2014, the regime can be called negatively stabile. The regime of Croatia can be called positively stabile, because multiple citizenship is continually accepted. Slovakia has the regime of negative changes because the positive stand towards multiple citizenship has become negative. The negative stand towards multiple citizenship has become positive in Latvia and because of that, the regime is of positive changes. Despite of lack of clearence in the legislation, the regime in Lithuania can be called of potential changes. This means that in present, the regime remains unchanged but the future likely brings changes into it. The countries can be compared in the basis of mode of citizenship acquisition. In other words, are there different rules for citizens by birth and by naturalisation in the topic of multiple citizenship. Slovakia has universally prohibited and sanctioned multiple citizenship to its citizens. In Latvia, all citizens can acquire multiple citizenship by certain countries. Multiple citizenship permission for all citizens is provided in Croatia but for naturalised citizens, the permission comes from different exceptions, not from universal rules. This gives citizens by birth and by naturalisation somewhat different status in Croatia. Estonia and Lithuania differ to an extent from the other countries. Both countries have clear prohibition of multiple citizenship for naturalised citizens. In Estonia, citizens by birth are expected not to have multiple citizenship but if citizens have it, the law does not contain any sanctions and constitution does not allow the state to deprive citizens of birth-right citizenship. Lithuania has limited also the multiple citizenship for citizens by birth. Despite of the prohibition of multiple citizenship in the constitution, it allows the citizenship law to stipulate exceptional and rare circumstances in which citizens by birth can have multiple citizenship. Because the constitution does not limit the circumstances, the legislator can be rather liberal. This has created a conflictual situation between the aim of the constitution and real life. The present citizenship law is a compromise between the two. 5 pos. = constitution has positive regulations towards multiple citizenship; neg. = constitution does not allow multiple citizenship 6 pos. = citizenship law allows multiple citizenship; neg. = citizenship law does not allow multiple citizenship 12

13 The constitutional regulation is positive or neutral towards multiple citizenship in 4 countries (Estonia, Latvia, Slovakia, Croatia). Neutral means there are minimal or no regulation. Positive and neutral regulation can mean permission to have multiple citizenship focused on emigrants (Croatia), the protection of citizens by birth against sanctions (Estonia) or leaving the whole topic to citizenship law (Slovakia). Latvian constitution does not restrict owning multiple citizenship but does not allow multiple citizens to become Latvian president. Only Lithuanian constitution is negative towards multiple citizenship. Even though, it gives the citizenship law an opportunity to allow rare occasions of multiple citizenship. In the citizenship law regulations the differences between countries are bigger. In 2014, 2 countries (Estonia and Slovakia) clearly prohibited multiple citizenship. The other countries have different levels of permission. Lithuania has universally prohibited multiple citizenship but on exceptional circumstances has allowed citizens to acquire other citizenships. Latvia has changed its stand towards multiple citizenship and allowed it in case of allied or friendly countries. Croatia has permitted multiple citizenship a long time, but due to external influence, the permission has expanded to all present and future citizens Media debates The following table consists of the general characteristics of media debate. This is followed by a brief discussion of the parameters. Estonia Latvia Lithuania Slovakia Croatia 1. Amount of articles Concentrated period of articles aug. 11 jan. 14 dec. 06 oct. 13 july. 09 nov. 13 may. 10 febr. 14 june. 07 dec Positions 7 in favor 19/31 21/24 19/25 21/42 6/7 against 12/31 3/24 6/25 21/42 1/7 4. Arguments, in favor keywords 8 against Overlap of arguments Appendix 2 Appendix 2 Appendix 2 Appendix 2 Appendix 2 6. Coalition in favor opposition 9 against Political parties 10 opinion 3/4 9/6 7/8 8/6 2/13 in favor 3/4 8/6 5/8 6/6 1/13 against 1/4 2/6 5/8 6/6 1/13 8. Politicians 11 opinion in favor 5/8 14/16 11/16 12/20 4/5 against 3/8 2/16 6/16 9/20 1/5 Table 5. Characteristics of media debates. Source: authors The first group formed on the basis of the amount of articles includes Slovakia and Estonia whose debate is continous and has not reached its final results. The second group includes Lithuania, who has defined the next step 12 and Latvia who has changed its attitude as a result 7 Percentage of arguments in favor and against from the whole of positions 8 How many different keywords are used in favor anfd against? 9 How many positions in favor or against belong to coalition or opposition? 10 The percentage of parties from the whole of 2014 parliamentary parties with certain position. 11 How many politicians have declared certain opinions (percentage from the whole)? 12 A referendum is planned to amend the constitution with the parliamentary election s in

14 of the debate. Croatia belongs to the third group because in the analysed period, there has not been any major change in the regime, the regulations hasbecome more specific and detailed. The study showed that the debate has in all countries been concentrated in the quite narrow timeframes (2-7 years by countries, between 2006 and 2014). Different groups can be defined on the basis of the length of that period or the location of the moment of publication. Generally these groups would be same as the groups defined by the amount of articles. The distribution of arguments in favor and against multiple citizenship among coalition and opposition shows the attitude of different forces in the political field towards multiple citizenship. In the sample of countries, there are countries where coalition parties have maintained the same attitude (Latvia, Lithuania, Croatia). In the rest of the countries, the coalition-opposition parties have changed their positions several times (Slovakia) or the positive-negative separation line has gone within the coalition (Estonia). In the countries where coalition parties have maintained a unitary attitude, the coalition are more positive towards multiple citizenship. The opposition in these countries have been rather against (Lithuania, Croatia) or equally in favor of it (Latvia). Coalitions in Estonia have been equally in favor and against multiple citizenship and in Slovakia rather against it. Oppositions in Estonia and Slovakia have been rather in favor of multiple citizenship. The distribution of arguments among political parties shows the activity of parties in he topic. 3 different groups can be defined here. In the first group, only a little part of parliamentary parties have declared an attitude (Croatia). In the second, almost all parties have presented arguments (Estonia, Lithuania). In the third group, the composition of parliament have changed several times and therefore more parties have declared an attitude than the parliament had in it in 2014 (Latvia, Slovakia). Same kind of groups can be defined if we consider only positive expressions. If we sum up parties which were positive and paries which were negative toward multiple citizenship, then the total in some countries can be bigger than the number of political parties which have expressed their opinion. The reason is that all the expressions of politicians have been considered and therefore the same party can at the same time be reckoned as in favor and against multiple citizenship. The individual level of politicians shows how many politicians consider multiple citizenship a worthy topic. The countries can be compared in 3 aspects. At first, the total number of politicians who have expressed their opinion in media. There are countries where only a few politicians have expressed their opinion (5 politicians in Croatia and 8 in Estonia) and countries where the number has been much larger (16-20 in Latvia, Lithuania, Slovakia). Secondly, we can compare the proportions of positively expressed politicians from the whole. One group consists of countries where it is roughly two thirds (Slovakia, Lituania, Estonia). The other group includes countries where nearly all politicians have a positive attitude (Croatia, Latvia). This shows that the expressions of politicians have been more positive in countries in positive attitude towards multiple citizenship. The same comparison can be made if we consider negatively expressed politicians. The groups include the same countries as previous aspect. Officially positively minded countries towards multiple citizenship have less politicians who have expressed negative opinions. 14

15 In all countries there have been more politicians who have positively expressed themselves than negatively expressed. Two countries (Lithuania, Slovakia) have the same situatsion in the individual level as in the parties level. It means that there are certain politicians whose statement can be different at different moments. The objective reason for this can be that politicians change their attitude accordingly to their position in the party (leader or regular member) or to the position of the party in the political field.(coalition or opposition). Nevertheless, this kind of situations ar rather exceptional but this explanation can be helpful Positive and negative positions The presence of the theoretical arguments supporting or opposing multiple citizenship in the media debates was empirically analysed. All the main theoretical arguments were also present in the debates as also outlined in the following table with empirically found wordings. Theoretical arguments in favor of multiple citizenship 1. Multiple loyalties are increasingly widespread, multiple citizenship is a way to recognize the real and perceived strong ties and loyalties. 2. There are more and more people who live in two or more countries and participate actively in the society. Their activity should be encouraged. 3. The open door policy will foster naturalisation and promote integration. Problems and conflicts between national communities can be overcome by cooperation and agreements. 4. Multiple citizenship promotes cosmopolitan, transnational values and loyalties. 5. The ban of multiple citizenship shows the state s negative attitude towards immigrants, permission facilitates free movement between Empirical arguments in favor of multiple citizenship 1. the laws should become more complied with real life and/or with the states constitution 2. people should have an opportunity to choose 3. the interests and comfort of citizens, reducing problems, increasing confidence 4. increases the circle of friends for the state 5. positive attitude towards emigrants and links with them 6. citizens are ambassadors of one country in the other and bearers of values 7. enabiling multiple citizenship must comply with Theoretical arguments against multiple citizenship 1. Loyalty is indivisible, only an unambiguous link between state and citizen can be of highquality. 2. The lack of clear ties between state and citizen complicates ensuring democracy and civil rights 3. Certain citizens will have more rights than other: voting in several places, single taxes but double benefits etc. 4. The chance to leave if things deteriorate in the country of residence. 5. Concern that immigrants threaten the national culture of the country of residence; biased voting, in particular, with large immigrant community. More conflicts on the basis of ethnicity, which affect the unity of the country. 6. Multiple citizenship slows down and reduces the integration of Theoretical arguments against multiple citizenship 1. citizenship bond cannot be multiplied, loyalty is indivisible 2. dangers the continuous basis of citizenship policy 3. condtional permission of multiple citizenship is unequal treatment of citizens 4. citizens with multiple citizenship have the chance to leave if the conditions deteriorate in the country of residence 5. increases foreign influence 6. decreases the integration of national minority 7. for citizens with multiple citizenship there 15