Worlds Colliding? Multiculturalism in Theory and Practice

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 60607 [email protected]

Annika M. Hinze: Worlds Colliding?

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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.


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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


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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


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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


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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


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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 conception1” 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


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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


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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


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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


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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


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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


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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)


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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


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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 all-

encompassing 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


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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


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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


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“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 principle2 closer to jus sanguinis3.

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.


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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


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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


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


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.


23

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Documents

Worlds Colliding? Multiculturalism in Theory and Practice