Worlds Colliding? Multiculturalism in Theory and Practice

Transcription

1 Worlds Colliding? Multiculturalism in Theory and Practice Immigration, Minorities and Multiculturalism In Democracies Conference Ethnicity and Democratic Governance MCRI project October 25-27, 2007 Montreal, QC, Canada Annika Hinze The University of Illinois, Chicago Department of Political Science (M/C 276) 1007 West Harrison Street Chicago, IL

2 The break-up of former Yugoslavia. Basque separatism in Spain. The Civil Rights struggle of African Americans in the United States. The Quebec question. Guest workers in Europe. Immigration. The question of minorities, their fair treatment and their entitlement to certain specific minority rights has been debated in scholarly literature for quite some time now. Different approaches to the treatment of minority groups and their issues within larger societies have been lumped together under the term multiculturalism. At the same time, however, by looking at different cases of minority rights and issues we might be surprised to see how different the issues of minorities are as well as the context in which minorities form and exist within societies. The contestedness of the term multiculturalism itself, it seems, stems from the fact that the literature on the topic relates to different specific national contexts, such as Canada, France, or the United States. While Charles Taylor (1994) is talking about the issues of the Quebecois, who were involuntarily incorporated into a British colony, Jürgen Habermas (1994) is thinking about voluntary immigrants to Germany, and Anthony Appiah (1994) has the issues of African Americans in the United States in mind. All three scholars talk about multiculturalism, all three scholars come up with different definitions. In this paper, I will address the question of multiculturalism and its different definitions within different national contexts. I will try to show that different national contexts indeed lead scholars to different definitions and perceptions of multiculturalism and the problems of its implementation. This is a methodological issue primarily. Using Sartori s ladder of abstraction as a solution to conceptual stretching, I will provide recommendations in how to solve this issue. Finally, I will explore the question of whether and in how far minority issues are comparable in the similar but different cases of France and Germany. 2

3 I Different Contexts Different Stories In dealing with the question of multiculturalism, different scholars have addressed the issue from the different perspectives of the countries in which they live or have referred to in their examples. This is where one of the main conceptual issues of the theory of multiculturalism stems from. Charles Taylor in his Politics of Recognition advocates a politics of difference, which gives recognition to the unique identity of an individual or a group, and emphasizes their distinctness. This politics of difference is meant to give individuals and groups a chance to express and emphasize their authenticity, which might be otherwise suppressed. The particular use of the word otherwise highlights the fact that Taylor advocates his politics of difference against a politics of equal dignity, which respects everyone equally but, in Taylor s view, makes everything universally the same ( ) an identical basket of rights and immunities (Taylor 1994, 38). Taylor views assimilation as a way of discriminating against cultural authenticity, which he advocates. Similarly, he advocates the politics of difference as a way to actually distinguish and differentiate. The claim is that the supposedly neutral set of difference-blind principles of the politics of equal dignity is in fact a reflection of one hegemonic culture. As it turns out, then, only the minority or suppressed cultures are being forced to take alien form. Consequently, the supposedly fair and difference-blind society is not only inhumane (because suppressing identities) but also in a subtle and unconscious way, itself highly discriminatory. (Taylor 1994, 43) In Taylor s view, a liberalism, which is based on individual rights and non-discrimination is particular to the Anglo-American world. However, in the case of Quebec, Taylor stresses not passive non-discrimination but actively 3

4 making sure that there is a community of people here in the future that will want to avail itself of the opportunity to use the French language. Policies aimed at survival actively seek to create members of the community, for instance, in their assuring that future generations continue to identify as French-speakers. ( ) Quebeckers, therefore, and those who give similar importance to this kind of collective goal, tend to opt for a rather different model of a liberal society. On their view, a society can be organized around a definition of the good life, without this being seen as a depreciation of those who do not personally share this definition. (Taylor 1994, 58/59) Taylor here explicitly refers to Quebec and the question of how to ensure the preservation of the French language and culture in this particular area of Canada. The Quebecois question has been strongly debated in the Canadian context and has given an important initiative for the implementation of a Canadian policy of multiculturalism. Understandably, Quebec is at the heart of the issue of the debate on multiculturalism for every Canadian. But what does this mean for the scholarly debate on multiculturalism which crosses borders and cultures? Non-Canadian scholars of multiculturalism, driven by the contexts they live in or investigate, might have a completely different take on the issue. Taylor advocates something that others (Habermas 1994, Appiah 1994) have called the artificial preservation of cultures. In other words then, Quebeckers not only opt for their own definition of the good life but also demand the right to assure that future generations will do likewise. Other scholars (Benhabib 2002) have critiqued this view by stating that in this model, future generations may not actually have the individual freedom of choice to not follow their ancestors and choose a different way of life. The point where Habermas most strongly disagrees with Taylor s Policy of Recognition is what he calls the artificial preservation of culture. Here, Habermas points out that cultural 4

5 heritages do and must produce and reproduce themselves a process in which the nation state cannot and should not be involved. Cultures, argues Habermas, can preserve themselves only through self-transformation. In other words, a culture must adapt to the spirit of the times and transform itself accordingly; it will cease to exist if it cannot adapt or transform, unless it is artificially preserved through the intervention of the nation state, which Habermas strictly argues against. The political integration in Habermas view, only political integration is necessary of citizens is supposed ensure loyalty to a common political culture. This is why Habermas advocates integration into a political culture before enabling new citizens to attempt to change the system in his view the loyalty to this common political culture will ensure productive and civilized debates about the best interpretation of constitutional rights and principles (Habermas 1994, 134). Accordingly, all that needs to be expected of immigrants is the willingness to enter into the political culture of their new homeland, without having to give up the cultural form of life of their origins by doing so. (Habermas 1994, 134, my emphasis) Habermas thus explicitly talks about immigrants. This shows that essentially Habermas and Taylor are talking about two different concepts. Habermas has in mind issues of immigration and integration in the European, or most likely in the German context. Taylor talks about the Quebecois in Canada and their rights to preserving their own culture. How can these two scholars even argue with each other when they are not addressing the same issue? Will Kymlicka (in Multicultural Citizenship, 1995) identifies two methods of minority protection and, concurrently, differentiated citizenship claims - one internal and one external. Internal 5

6 protection refers to the protection of certain group values against members of that group attempting to change or undermine those values. These claims, according to Kymlicka, may be non-legitimate claims. In some cases, these claims might even violate basic individual rights as they might deprive certain group members of rights they are entitled to within a democracy. An example of this might be the inferior treatment of women in certain cultural groups. To be part of a certain cultural group, women might be deprived of certain democratic rights to gender equality. External protection signifies the protection of certain group values against the rest of society in terms of differentiated citizenship rights a claim that, according to Kymlicka, may be legitimate. Kymlicka differentiates between voluntary immigrants to a country and those, whom he defines as a nation involuntary colonized or incorporated within another nation. Voluntary immigrants (following Walzer and Glazer) have limited rights to differentiated citizenship claims in this view, whereas Kymlicka attributes an undeniable right to differentiated citizenship claims to involuntary colonized peoples. Voluntary immigrants, or, in Kymlicka s terms, polyethnic groups, have voluntarily uprooted themselves in order to live in a new culture. They cannot be attributed differentiated citizenship rights as nations. However, in Kymlicka s view, they should be entitled to certain polyethnic group rights within the dominant society. Once again, we can see how the context in which Kymlicka works out his view of multiculturalism is extremely influential in his theory-building. He makes a point of addressing the issues of nations involuntarily colonized or incorporated into another nation (i.e. Quebec) and differentiating between their group rights and the rights of voluntary immigrants. It is important to acknowledge that Kymlicka (unlike other scholars) is able to make a distinction between 6

7 immigrants and nations incorporated into other nations. At the same time, however, Kymlicka s view of minority groups (whether they are immigrants or nations) is still strongly influenced by the Canadian context. Benhabib (2002) argues that Kymlicka, though strongly advocating the distinction between national minority groups and voluntary immigrants, fails to clearly differentiate between them. By advocating group and representation rights for all minorities, according to Benhabib, Kymlicka is, maybe unintentionally, assuming that cultures represent homogeneous wholes : Cultural practices rarely reach the level of coherence and clarity that a theorist, as opposed to a practitioner, can tease out of first-level articulations and engagements. Any collective experience, sustained over time, may constitute a culture. Why privilege institutionalized cultures over ones that may be more informal and amorphous, less recognized in public, and perhaps even of origin that is more recent? (Benhabib 2002, 61) Benhabib bases her concept of culture and multiculturalism on Habermas discourse ethics, thereby expanding the theory. She views the constitution of the self as narrative and dialogic in nature (Benhabib 2002, 16) defining discourses as deliberative practices that center not only on norms of action and interaction, but also on negotiating situationally shared understandings across multicultural divides (Benhabib 2002, 16). The mosaic conception 1 of multiculturalism, which dominates Taylor s and Kymlicka s works, is seen by Benhabib as an (unsuccessful) attempt to define one master narrative that of culture as more important than other narratives in the constitution of the identity of the individual. The attempt to construct culture as something internally uncontested and pure, argues Benhabib, is reflected the desire to understand the self as something equally harmonious and unified: harmonious beings with a 7

8 unique cultural center (Benhabib 2002, 16). Conversely, Benhabib strives to see the self, just as its culture as something conflicted, contested, and contradictory. During the span of a lifetime the self is confronted not only with one but with many, possibly contradicting, narratives, leading to a more dynamic personal identity, which is subject to change. Likewise, group identities are contested and internally diverse, they are subject to change over time. Benhabib argues that n a globalizing world, where the confrontation, and along with it the hybridization of cultures is increasing, fundamentalist and nationalist claims in defense of traditions will grow. The nation state might lose much of its significance, which will contribute to the importance of group identities and rights. Yet, while the nation state still exists, Benhabib predicts its greatest challenge as: To retain their [liberal democracies ] dearly won civil liberties, political freedoms, and representative deliberative institutions, while defusing the fundamentalists dream of purity and of a world without moral ambivalence and compromise. The negotiation of complex cultural dialogues in our global civilization is now our lot. (Benhabib 2002, 186) Benhabib addresses the phenomenon of globalization, the hybridization of cultures and the increasing confrontation of different groups and identities with one another. Hence, Benhabib talks about migration, about diasporic cultures, and the potentially shrinking significance of the nation state. She does not talk about nations within nations, such as Quebec in Canada. Within the context of her argument, Benhabib stresses the hybridity of cultures, and the infinite variety of different cultural and ethnic groups within themselves. She also accuses Kymlicka of portraying and viewing cultures as homogeneous wholes. Kymlicka, however, has quite a different issue in mind than Benhabib. Kymlicka seeks to differentiate the issues of the Quebecois from the issues of ordinary immigrants. The Quebecois, at the same time, could 8

9 most likely be considered to be a much more homogeneous group than groups of immigrants that come from different corners in their country of origin and end up dispersed all over the new country to which they migrate. The Quebecois have lived in one concentrated area of Canada as one quite homogeneous group for a long time and do not quite fit the description of hybrid, territorially dispersed and diasporic cultures that Benhabib talks about in the context of globalization. Thus, Benhabib and Kymlicka are attempting to address different issues, and they pursue different aims with their work. While Kymlicka is concerned with the issues of the Quebecois and the way that these issues differ from those of immigrants, Benhabib promotes awareness of the changing conditions of migration, cultural awareness and identity and the different role of the state itself in the era of globalization. What I have attempted to show here is that these four different scholars may all claim to address the issue of multiculturalism, but their sometimes fundamental disagreements stem from the fact that they all address the theory of multiculturalism from different practical contexts and standpoints. In other words, all four scholars claim to address the same concept, but they in fact do not at all. II A Conceptual Problem How should we study multiculturalism then? If each theoretical approach to multiculturalism is in fact based on a very specific context, should we give up the desire to create a general theory of multiculturalism? Each approach, the particularist approach of studying each specific encounter between a minority group and the host population, as well as a more general approach to each case, has its drawbacks. As researchers in political science, we are forced to make some fundamental decisions about how to deal with human behavior and its predictability. Are 9

10 political scientists in a position at all where to build general, overarching models that can help them to understand human behavior accurately? Or should we approach cases in a more anthropological fashion? A fundamental issue with human behavior in general is the gap between theory and practice. We can build grand theories based on very general models of human behavior, of the customs of social groups, and the interactions of states as larger units, but we will always find deviant cases, which our models cannot explain. We also might have to deal with too much variation within our category (= conceptual stretching). Let me demonstrate this with a simple example. Take the study of Muslim minority groups. In this case, at the outset, there is an issue with the unit of analysis, because it is not clear whether we would be able to generalize all Muslims within a certain society as Muslim minority group. In different Western societies that are host to Muslim groups, we are much more likely to find a variety of Muslim groups within one society. For example, there might be Sunni Muslims, Shiite Muslims, Alevis as well as very conservative Muslim communities, and less conservative communities. In addition to that, we will find communities that would define themselves as Muslim but even more so might define themselves by their nationality of origin or their national heritage. Hence, some Turks in Germany might identify themselves as Eastern Anatolian immigrants from a specific region more so than as specifically Muslim, though they would acknowledge to being Muslims as well. Further, Turks and Kurds from Turkey would probably find that they have not much in common at all, though they are both mostly Muslim groups from Turkey. In addition, Muslim immigrants to Western countries differ from country to country. In Germany, the vast majority of immigrants are from Turkey, while French Muslim immigrants are predominantly from the Maghreb with only a very small Turkish minority living in France. In Britain, the majority of Muslim immigrants are from 10

11 India and Pakistan and from some Far Eastern countries. Furthermore, minority groups may be generalized in theory as minority groups only. However, how much do French Canadians, African Americans, and German Turks really have in common regarding the problems they face (and have faced) within their host societies? French Canadians blend in ethnically to the greatest extent. They don t carry a stigma because of their skin color or appearance. African Americans do not consider themselves an immigrant group, and they do not differ from the rest of the population by the language they speak. German Turks are mostly stigmatized by their religion, as well as by the fact that they are a more recent immigrant group, who by a vast majority until recently could not acquire citizenship and be represented adequately within the polity. Is there a middle road to how we can approach multiculturalism despite the variety in particular cases? Can we construct more general theories about the integration of minority groups at all? I think that this is an important part for a discipline of political science to have some overarching theories upon which we can orient ourselves. Though political scientists sometimes might turn into anthropologists when studying particular cultures and their dynamic, we should not rely on that approach only. Constructing theories about political science is necessary and important, and it should not be something we should neglect to do completely just because we are dealing with many issues that are particular to certain circumstances, even when we are dealing with the issue of minority integration. Will we not lose sight of overarching phenomena if we start to only deal with very particular cases one by one? On the other hand, as I have demonstrated, we can hardly expect that a theory particularly constructed in the face of minority issues in Quebec and the preservation of the French language in Canada will completely capture the issues of and suggest a fair way to deal with the issues of Turkish minority groups in Germany. I am saying completely here, because I think that there might be a chance that a theoretical approach to the Quebecois in 11

12 Canada might capture certain aspects that may partly apply to German Turks and Turkish immigrants in Germany as well. So, is there a methodological middle road? An interesting approach in dealing with the practical (or theoretical) gap between overarching theories and specific cases in terms of integration of minority groups specifically, is Giovanni Sartori s ( Concept Misformation in Comparative Politics., 1970) approach to conceptual stretching: Sartori s argument is that, for example, pluralism, integration, participation, and mobilization are clearly defined within the Western context, but the clear meanings of those terms is lost or begins to overlap in a different, global context. The universal and unspecified application of terms such as pluralism and integration can lead to dramatic errors in prediction and interpretation. Much of the work within the discipline suffers, in this view, from the meaningless togetherness and dangerous equivocations and distortions. We could go even further than Satori and argue that, as we have seen in the above examples, the issues around the integration of minorities is not even accurately defined within the Western context, and this definition is bound to become increasingly less accurate in the face of globalization. Can Satori s concept solve the problem of the gap between theory and practice when it comes to the issues of minority groups? Sartori claims that conceptual stretching can be avoided depending on how specific the concept is that is addressed: The problem can be neatly underpinned with reference to the distinction and relation, between the extension (denotation) and the intension (connotation) of a term. A standard definition is as follows: The extension of a word is the class of things to which the word applies; the intension of a word is the collection 12

13 of properties which determine the things to which the word applies. 1 Likewise, the denotation of a word is the totality of objects indicated by that word; and the connotation is the totality of characteristics anything must possess to be in the denotation of that word. (Sartori 1970, 1041) Hence, if intension is diminished, it automatically expands the extension of a category to include more different cases. Of course, this is not without theoretical drawbacks either. The concept, once we diminish the attributes it is supposed to refer to, may be applied more generally, but it will also tell give us less specific information about all the cases it applied to. It immediately becomes a question whether a concept with minimal intension and great extension will be all that useful to us in the first place then. However, we are able to move up and down the ladder of abstraction, and adjust our concepts accordingly. For example, we would expect that Turks in Germany and North African immigrants in France face much more similar issues in terms of integration than do French Canadians. Obviously, Germany and France still have different policy approaches regarding their immigrant groups; the two countries differ in terms of immigrant history as much as the two immigrant groups differ in terms of nationality, in terms of their reasons for and avenues of immigration, and issues of inclusion, assimilation, and participation in the two countries. However, in comparison to the Canadian case, both immigrant groups (German Turks and French North Africans) find themselves different from the majority groups in their countries in terms of nationality (in some cases), in terms of religion, and outward appearance (skin color, religious symbols, etc.). Thus, we could probably increase the intension of our concept, if we included Turks in Germany and North Africans in France, but excluded French Canadians. If we wanted to 1 Salmon, Wesley C.: Logic. Prentice Hall, Englewood Cliffs, 1963, pp.90-91, quoted in Sartori (1970) 13

14 include the Quebecois, we would have to decrease intension and end up with a concept that is very general but would contain a minimal amount of information. I use this example to make it clear that though it may be a conceptual problem to generalize from the French Canadian case (as Kymlicka and Taylor have done) to all other cases of minority rights, the Canadian case may still have some commonalities with other cases. This means, in turn, that we do not have to discard all our concepts. However, we have to be very careful in terms of applying very specific categories. For example, when it comes to the application of group rights for French Canadians, to a great variety of cases (i.e. minority populations in general ), the specific history of the French Canadian case, and the special awareness of Canadian scholars in this context, will cause them to come to conclusions that will not necessarily be applicable to minority groups elsewhere. Will Kymlicka seems somewhat aware of this problem when he suggests that there should be a difference between involuntarily colonized groups and voluntary immigrant groups in terms of how many individual group rights we attribute to them. However, as I have mentioned before, there may be certain communalities of immigrant groups in general, which we can capture conceptually in very general terms. Further, we may find more commonalities between a certain two or three immigrant groups than between others. Concepts that refer only to these groups will be more specific. Depending on how general we want our concept to be, we can move up and down the ladder of abstraction, giving our concepts less specific attributes to make them more general, or giving them more specific attributes to make them more specific and informative. Despite our responsibility as scholars to create general theories, should we acknowledge the detail of social construction specific to each encounter? I would respond with yes, absolutely, in 14

15 order to be able to give meaningful answers to our own research questions about specific places, interactions, and dynamics, and to understand the issues of minority groups in specific places. We must try and avoid conceptual stretching and acknowledge the fact that each cultural, social, and political encounter between a majority and minority group is shaped by the dynamic among these particular groups, their characteristics, their histories, and their rules of interaction. This precondition, however, should not keep us from forming general concepts. What we have to be careful about is how many attributes we should include in a concept that we want to be as allencompassing as possible. If we find our concept too general and not really informative, we might want to consider narrowing down the number of cases we want it to apply to. Another option would be to supplement a general concept with specific information about two or more different cases that are both captured by the same general concept but may display great particular difference. We might for example argue that all minority groups (simply because they are minorities) are faced with a certain issue of adequate political representation. We may then show that minority groups that are condensed territorially (as the Quebecois) have a better chance for collective political action and representation than say African Americans, who are more territorially dispersed across the country, and who face the additional issue of gerrymandering (to their advantage or disadvantage depending on the current administration) and majority voting districts in their quest to gain better voter representation as a minority group. Human behavior cannot be measured by rules as generalizable as those that can be found in the natural sciences. Hans Georg Gadamer (1989) recognized that when he found that truth and method in the humanities were at odds with each other and criticized the fact that methodology in the humanities was increasingly modeled after the natural sciences. He also recognized that the author of any scientific text has a historically shaped consciousness, which has evolved 15

16 through the specific cultural and personal experience shaping each human being. We can expand this view to the inherent tension in the way that scholars understand the issue of minority groups and the majority population within the context of what they have experienced or studied and the way that this understanding is often generalized like a mathematical rule to the dynamic between any other majority and minority group. In the Behavioral Sciences, we can only go so far in terms of finding grand theories and concepts that explain the dynamics of human behavior. The most important thing, it seems then, is for us to beware of generalizing from specific findings. Rather, we should look at the variety of cases that we are including in our generalizations about our specific findings. Most likely, what we sought to generalize to will have to be adjusted if an all-encompassing concept is to be established. The middle road to multiculturalism would then require two things: a generalizable definition and consensus on what multiculturalism actually is, with regards to different contexts, as well as the awareness that policy recommendations must be case-specific and can hardly be generalizable in the case of multiculturalism. III - Two European Cases: France and Germany In the last part of this paper, I want to see how comparable two countries, which could be characterized of having similar issues regarding their minority populations, really are. Germany and France have been described and cited as two opposite approaches to citizenship. France has been characterized as the classic example of a civic nation, where based on the respect for and identification with the French Republic, technically anyone can become a good Frenchman. Germany, on the other hand, has been viewed as a classic example of the 16

17 ethnic nation, where national identity is rooted in blood and ancestry and cannot be acquired through practice but only be inherited by blood. Thomas (2001: 6) argues that If ethnic nations are based on decent, civic nations which are supposedly their opposite must, therefore, be based on consent. However, France s and Germany s approaches at first sight are not as clear-cut as the concepts they stand for, especially in the light of the most recent immigration policies and debates in both countries. France s perceptions of immigrants has been mixed for a while. Since colonial times, there had always been the perception of particular inferiority of North African colonial subjects as opposed to other Caucasian immigrant groups. Clifford Rosenberg (2004) describes Albert Sarraut, who led France s Interior Ministry between World War I and World War II and exerted tremendous influence regarding French immigration policy at the time. By the interwar years, North Africans had replaced Italians as the most recent immigrant group in French public opinion. Employed in the most unpleasant, poorly paid, dangerous positions, North Africans were disdained not only by French workers but by other immigrants as well. ( ) Their anxieties about degeneration and racial mixing led them to impose formidable administrative hurdles to limit the number of North Africans on the French mainland, and to monitor all who made the journey with a series of invasive hygiene programs. ( ) Their political commitments powerfully influenced their perception, and ultimately their treatment, of those colonial immigrants during the interwar years and for generations to come. (Rosenberg 2004, 48-49) In fact, North African immigrants were said to be less adaptable to French culture and French Republican values than European immigrants and therefore less desirable immigrants all together (Rosenberg, 2004). Despite this, France has retained a relatively open immigration policy. This policy, however, goes along with the expectation of all immigrants to become 17

18 good Frenchmen and adhere to the values of the Republic, which means, above all, secularism. These values oftentimes clash with the religious attachments of many immigrants from France s former colonies in the Maghreb. In addition to the religious conflict around Islam, which has been prevalent in France especially with regards to the headscarf, the election of Nicolas Sarkozy as French president in 2007 has brought about speculations of a change in French citizenship law, away from the more open jus soli principle 2 closer to jus sanguinis 3. In Germany, since the founding of an official German state in 1871, citizenship was tied to German blood and ancestry only. This long tradition as an ethnic nation was changed in 1999 with a new citizenship law. The ancient citizenship law dating back to 1913 was finally abandoned, and immigrants, who have lived in Germany legally for a certain amount of time, as well as their children, can now acquire German citizenship. This has come as an improvement in the situation of many former Turkish guest workers. Turkish immigrants started coming to Germany in the late 1960s as part of Germany s guest worker program, through which a number of low-skilled workers were hired from Turkey and the Mediterranean. Upon their arrival, those guest workers stayed in barracks separate from the German population and were intended to be sent back to Turkey after their work was done. Many of those former guest workers ended up staying in Germany for generations, and have now become German citizens or permanent residents. Germany still grapples with the full integration of many of its Turkish immigrants, who are confronted with the stigmas of not being European and Islamic. Tellingly, Germany until recently defined itself as kein Einwanderungsland (not a country of immigration). This is hardly the case. The German 2 The right of soil, granting each individual born on French soil French citizenship. 3 The right of blood, granting only those of French ancestry/french blood French citizenship. 18

19 Ministry of the Interior estimates the number of foreign nationals living in Germany to be around 7.3 million, about 9% of the total population. Despite its more inclusive approach to citizenship, Germany is experiencing a debate particularly around Islam in the public sphere, which marginalizes those former Turkish immigrants, who are citizens because of their religion and culture. The controversy around the headscarf in Germany is a more recent one than in France but the arguments are the same for both. Both, France and Germany, are also experiencing the impact of an overarching EU-policy towards migration within the EU. That means that any citizen of any of the EU-member states can freely move around the EU, but those immigrants from outside the EU still face heavy restrictions. This means that immigrants of North African decent in France and Turkish immigrants in Germany face much higher restrictions to entering either country than immigrants from, say, Greece or Italy. Do Turks in Germany and Maghrebis in France face similar issues, particularly in terms of the stigma that goes along with their religion? Can policy recommendations for the implementation of a more tolerant policy towards these minority groups in these two very particular cases be the same? I am well aware of the fact that Muslims are not just Muslims. In other words, the Muslim religion is characterized by an immense variety. Within it exist many different Muslim faiths and cults as well as radically different interpretations of the Koran. Similarly, as Benhabib (2002) has argued, not all the minority groups in Germany and France are homogeneous wholes. Turks in 19

20 Germany are not just Sunni Muslims, they are Shiites, Alevis, or secular. The same is true for North Africans in France they are no homogeneous bloc and come not only from different religious, but also from different national traditions. As different as these immigrant groups may be, however, they face similar barriers from the dominant population groups in both countries. What is key here is to take into consideration not just the way the groups of immigrants differ in both countries and within themselves, which is very important to note, of course, but also the way those immigrants are perceived by the dominant population group in the country. Perception, in this case, may be influenced by the dynamic between the dominant and the minority group in a certain country. It might be shaped by the way the media and influential politicians construct the image of a minority group in an either favorable or unfavorable way, and the way the minority group reacts to this image construction. This kind of reasoning is based on the assumption that groups and societies do not divide along ethnic lines because of deeply held primordial identities, attachments, and values, that issues, problems, interests, and identities are not soundly anchored to an objective empirical reality but are themselves images or reality created through discursive processes that define or assign meaning to social phenomena; that is they construct social reality (Croucher 1997, 173). In this view, the dynamic between minority and majority groups within a society is socially constructed and constantly in flux through action and reaction. This dynamic, but especially the way that Turkish immigrants in Germany and Maghrebis in France are perceived by the dominant population group, is what is really comparable in France and Germany. In other words, both groups in both countries might face similar issues in terms of the socially constructed dynamic between the European majority group and the Muslim minority group, whose difference on the side of the Europeans is predominantly observed based on their religion, whether the minority group explicitly identifies 20

21 itself as Muslim or not. The headscarf is an interesting example of this. The headscarf has become a symbol for the otherness of Islam in comparison to the West on both sides. It represents the grounds for rejection of the other by the West (portraying Islam as intolerant and discriminatory) and it symbolizes the resistance of the other against the West and its portrayal as inferior by the West. The point here is the fact that the role that Islam plays in the way that it is portrayed by the West as well its role as an identity of resistance against the West is merely an image and a social construction, and it is also the point on which the French and the German case are quite comparable. VI - Conclusion The awareness about the possibilities and pitfalls of comparison as well as the specificities of different countries is what may lead to more helpful policy recommendation and a more differentiated and case-specific definition of a multiculturalist policy. What I have attempted to illustrate in my reference to the cases of France and Germany is the idea that by knowing the details and divergences of both cases, we might more easily identify aspects that both cases have in common. The approach to concepts such as multiculturalism through a middle road between an abstract and general concept and the specificity of particular case studies might be a key factor in theory building around certain issues and the construction of policy recommendations that really fit specific cases. Awareness of the differences between the German and the French case might lead us to certain commonalities between the two cases. At the same time, however, it is important to be aware of the fact that the issue that France and Germany grapple with is a very specific one, and that its adaptability to other national contexts may be extremely limited. It seems that precisely because the theory of multiculturalism is so 21

22 closely related to specific national contexts and policy recommendations about a policy of multiculturalism, it is especially important that we become aware of the inherent difference of issues of integration within different national and historic contexts. Maybe then, we might see a lesser divide between theory and actual social reality. 22

23 Bibliography Appiah, K. Anthony: Identity, Authenticity, Survival: Multicultural Societies and Social Reproduction. In: Multiculturalism. Examining the Politics of Recognition. Edited by Amy Gutman. Princeton University Press, Princeton, NJ Benhabib, Seyla: The Claims of Culture. Princeton University Press, Princeton, NJ, Brubaker, Rogers: Citizenship and Nationhood in France and Germany. Harvard University Press, Cambridge, MA Bundesministerium für Inneres (German Federal Ministry of the Interior): Statistics. Croucher, Sheila L.: Imagining Miami. Ethnic Politics in a Postmodern World. University of Virginia Press, Charlottesville & London, Gadamer, Hans-Georg: Truth and Method. Second Revised Edition, Continuum: London, New York, Habermas, Juergen: Address: Multiculturalism and the Liberal State. Stanford Law Review, Vol. 47, No. 5 (May 1995), pp Habermas, Juergen: Struggles for Recognition in the Democratic Constitutional State. In: Multiculturalism. Examining the Politics of Recognition. Edited by Amy Gutman. Princeton University Press, Princeton, NJ Kymlicka, Will: Multicultural Citizenship. Clarendon Press, Oxford, 1995 Rosenberg, Clifford: Albert Sarraut and Republican Racial Thought. In: Race in France, Berghahn Books, 2004, pp

24 Sartori, Giovanni: Concept Misformation in Comparative Politics. The American Political Science Review, Vol. 64, No. 4 (Dec. 1970), pp Taylor, Charles: The Politics of Recognition. In: Multiculturalism. Examining the Politics of Recognition. Edited by Amy Gutman. Princeton University Press, Princeton, NJ Thomas, Brook: Civic Multiculturalism and the Myth of Liberal Consent. A Comparative Analysis. The New Centennial Review, Vol. 1, No. 3 (2001), pp Touraine, Alain: Can We Live Together? Equality and Difference. Stanford University Press, Stanford, CA Walzer, Michael: Comment. In: Multiculturalism. Examining the Politics of Recognition. Edited by Amy Gutman. Princeton University Press, Princeton, NJ