On the list of hyphenated citizenships the‘multicultural’ one certainly takes a promi-nent place. It signals a general concern forreconciling the universalism of rights andmembership in liberal nation-states with thechallenge of ethnic diversity and otherascriptive ‘identity’ claims. In this chapter, Ifirst discuss multicultural citizenship intheory, pointing to the shortcomings of both‘radical’ and ‘liberal’ approaches to justify-ing minority rights under the generic, andparadoxical, notion of multiculturalcitizenship. Secondly, I look at the ways inwhich multicultural citizenship has beenpracticed in liberal nation-states. This inves-tigation reveals a gap between the theory andthe practice of multicultural citizenship: amechanism to accommodate ethnic, national,and other minorities in theory, multiculturalcitizenship in practice has been a variant ofnation-building in a few new settler societieswithout independent founding myths. Inaddition, I argue that the state-centerednotion of multicultural citizenship deflectsfrom the decentered accommodation ofmulticultural minority claims in functionallydifferentiated societies, which remains shortof official state recognition. Considering thedifficulties of grounding multicultural citizen-ship in theory, and considering the diverseand often contested practices that it seeks toencompass, I conclude that the notion ofmulticultural citizenship is too vague and

multifaceted to be a useful tool of sociologi-cal analysis. It also runs counter to a trendtoward de-ethnicization in liberal states, inwhich the cultural impositions of the major-ity on minority groups are growing thin, thusremoving the case for minority rights.

MULTICULTURAL CITIZENSHIPIN THEORY

A good way of approaching multiculturalcitizenship is to explicate its critiqued ormodified opposite. One influential authorhas identified the latter as ‘universal citizen-ship’ (Young, 1989). Universal citizenshiprefers to the equality of rights and status thathave come to define membership in liberal-democratic nation-states: ‘citizenship foreveryone, and everyone the same qua citizen’(Young, 1989: 250). Universal citizenship,product of the French and American revolu-tions, has its own historical opposite: thetiered and multiple subject statuses and theparticularistic rights and duties attached tothem under feudalism. In fact, ‘universalcitizenship’ is a pleonasm, because univer-salism as the rejection of particularistic rightsand statuses is constitutive of citizenship assuch. Accordingly, universal citizenship ismeaningful only if viewed as the opposite ofmulticultural citizenship. The latter is thus

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paradoxical, because it seeks to (re)particu-larize a form of membership that is inher-ently universalistic.

From a different point of view, the notionof universal citizenship is not a pleonasm, butan oxymoron. As long as there is no worldstate, citizenship means membership of aparticular state. Citizenship as state member-ship is ‘inherently group-differentiated’(Kymlicka, 1995: 124), and thus the exactopposite of ‘universalist.’ This ambivalenceof ‘universal citizenship,’ to be eitherpleonasm or oxymoron, reflects the dualnature of citizenship as both ‘internally inclu-sive’ and ‘externally exclusive’ (Brubaker,1992: Ch. 1). The distinction between inter-nal and external aspects of citizenship pointsto an important limitation of the meaning ofmulticultural citizenship: to the degree thatthe latter is a commentary on the short-comings of universal citizenship, it focusesonly on the internal rights dimension, andtakes no account of the external state-membership dimension of citizenship.

The abstraction from the external dimen-sion of citizenship in most discussions ofmulticultural citizenship is puzzling. Afterall, the multiplication of cultures and ethnicgroups within contemporary nation-states islargely the result of cross-border migrations,which is partially shaped by (and, in turn,impacts on) a state’s formal citizenship lawsand policies. In multicultural citizenship’smost concise formulation (Kymlicka, 1995),special group rights (for immigrants, forexample) are compensation for axiomaticallyassumed strong nationalizing practices evenin contemporary liberal states, which are saidto have a discretionary ‘right … to determinewho has citizenship’ (Kymlicka, 1995: 124).As Kymlicka provocatively argues, this rightof states ‘rests on the same principles whichjustify group-differentiated citizenship withinstates,’ and ‘accepting the former leads logi-cally to the latter’ (1995:).

Following the same logic, a relaxing ofthe axiomatically assumed state discretionon citizenship would remove the mainjustification for group rights. In light of aliberalization of citizenship law across

immigrant-receiving Western states (seeWeil, 2001), which is part of a larger trendtoward de-ethnicization in such states(see Joppke and Morawska, forthcoming:Ch. 1), there is evidence that this is actuallyhappening. However, by focusing only onthe internal rights and ignoring as an invari-able parameter the external state-member-ship dimension of citizenship, Kymlickahas ruled out by design the possibility ofchanges in the external aspect of citizenshipimpacting on its internal rights dimension.In sum, a proper assessment of multicul-tural citizenship has to take account of boththe internal and the external dimensions ofcitizenship.

Before elaborating on this, it is importantto note that current versions of multiculturalcitizenship differ in their relationship touniversal citizenship. For feminist and(post)Marxist radicals, the relationship isone of critique and substitution (Young,1989, 1990); for liberals, it is one of com-plementarity and linear addition (Kymlicka,1995; Carens, 2000). The thrust of IrisMarion Young’s radical formulation is todenounce the ‘universal’ in universal citi-zenship as the disguised particularism of thedominant group(s). ‘Oppression’ is key toher scenario: society is seen as composed of‘social groups,’ which are either dominantor oppressed. Not much is said about thedominant group(s) (is it one or several?),despite occasional reference to ‘white middle-class men’ (Young, 1989: 268). This omis-sion is perhaps not accidental, because thedominant can hide their groupness under thecloth of universalism. ‘Differentiated citizen-ship,’ which for Young is mostly aboutspecial representation rights in the polity, isreserved for ‘oppressed’ groups, wherebyoppression is defined rather broadly asincluding anything from economic exploita-tion to cultural discrimination.1 From thisbroad definition of oppression follows a longlist of groups entitled to differentiated citi-zenship: ‘Women, blacks, Native Americans,Chicanos, Puerto Ricans and other Spanish-speaking Americans, Asian Americans, gaymen, lesbians, working-class people, poor

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people, old people, and mentally andphysically disabled people’ (Young, 1989:261). Without any commentary, a secondlist adds ‘young people,’ while dropping‘Asian Americans’ (1989: 265). Theunderlying reasoning is apparently ad hoc;and ‘differentiated citizenship’ for whatturns out to be the vast majority of the USpopulation seems a rather impracticableidea.

Young’s failure to come up with a moreconcise definition and elaboration of whatconstitutes an ‘oppressed group’ is instruc-tive.2 It shows the difficulty of building atheory of multicultural citizenship aroundthe notion of ‘oppression.’ This notion is toovague and simplistic to account for theasymmetries of power and resources incomplex societies. As an inherently polemi-cal (or ‘critical’) concept, oppression thriveson its (utopian) opposite, the absence ofoppression. Has it ever existed? Can it existat all, particularly if group differentiation isnot only an inevitable but a ‘desirableprocess’ in modern societies (Young, 1989:261)? Why should oppression stop whenThe Others are in charge? Finally, there is asystematic ambivalence about the inclusiveor exclusive thrust of differentiated citizen-ship, and thus about its relationship to itscritiqued opposite, ‘universal citizenship.’ If‘universal’ is just a smokescreen for domi-nant group interests, the purpose cannot beinclusion into this false universal (as it hadbeen in the – negatively evaluated – ‘eman-cipatory momentum of modern politicallife’ 1989: 250). Accordingly, the quest fordifferentiated citizenship is presented as a‘politics of difference’ that rejects tradi-tional ‘inclusion’ (Young, 1990: Ch. 6).However, in other places the whole point ofdifferentiated citizenship is still seen as‘mak[ing] participation and inclusion possi-ble’ (Young, 1989: 273). Inclusion intowhat, one is inclined to ask, if existing insti-tutions and representations (such as ‘universalcitizenship’) are just instruments of domi-nant groups.

The notion of oppression does not figurecentrally, in fact, hardly appears at all, in

Kymlicka’s (1995) liberal alternative ofmulticultural citizenship. Furthermore, forKymlicka the relationship between univer-sal and multicultural citizenship is not oneof critique and substitution, but of simpleaddition. Rather than being subjected to aradical critique, universal rights are fine; theproblem is that they are not enough forcertain groups: ‘A comprehensive theory ofjustice in a multicultural state will includeboth universal rights, assigned to individualsregardless of group membership, and certaingroup-differentiated rights or “special status”for minority cultures’ (Kymlicka, 1995: 6).

Whereas Young’s key concept wasoppression, Kymlicka’s is ‘societal culture.’Individuals need societal culture as a con-text of meaningful choices: without it thereis no freedom (Kymlicka, 1995: Ch. 5). Inaddition, access to a societal culture canbecome an issue of equality and justiceunder certain circumstances (1995: Ch. 6).No state, not even liberal states, can be cul-turally neutral; for example, in its selectionof an official language a state inevitablypromotes the majority culture, at the cost ofthe culture of minority groups that may residein the same territory. Given the inevitablenexus between state and majority culture,the traditional liberal answer to ethnic andcultural difference, ‘benign neglect,’ is notenough: liberal justice requires special rightsrecognizing and protecting the cultures ofminority groups.

Kymlicka’s distinctive contribution hasbeen the liberal mainstreaming of minorityrights. After Kymlicka, the earlier con-frontation between liberal defenders of uni-versal citizenship and radical proponents ofmulticulturalism and group rights has lost itsbasis: it is not a radical critique of existinginstitutions, but those liberal principles onwhich existing institutions are built thatrequire multicultural citizenship.

It is therefore worth scrutinizing thistheory in more detail. A crucial difference toYoung is the drastic narrowing of the minor-ity groups entitled to special rights: onlyethnic and national minority groups qualify.This is due to a narrow definition of the

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conditioning factor of group rights, ‘societalculture.’ Kymlicka defines societal cultureas shared history, language, and territory,making it ‘synonymous with “a nation” or“a people” – that is, … an intergenerationalcommunity, more or less institutionallycomplete, occupying a given territory orhomeland, sharing a distinct language andhistory’ (Kymlicka, 1995: 18). This defini-tion excludes non-ethnic groups, such asgays and lesbians, the disabled, or lifestylegroups, as multicultural claimants (seeKymlicka, 1998: Ch. 6).

However, the claims of the only two legiti-mate multicultural groups in Kymlicka’sliberal scenario, national minorities andimmigrants, differ in significant ways. And,as I would like to add critically, they differin ways that ultimately militate against thevery notion of multicultural citizenship.National minorities, such as the Catalans inSpain, the Quebecois in Canada, or theAborigines in Australia, have the strongestclaims within Kymlicka’s scheme. All ofthem have ‘institutionally complete’ cultures,that is, cultures that cover the full range ofhuman activities, needs, and functions(1995: 78). Moreover, as the victims ofnation-state building, they are forced toreside in states that do not carry the marks oftheir culture (most notably, their language).To accommodate the always potentiallysecessionist national minorities withinmultinational states, strong ‘self-governmentrights’ are required, and also justifiable froma liberal point of view. Kymlicka does nothide the fact that these rights pose a seriousthreat to the integrative function of citizen-ship, because their thrust is separation, notintegration (1995: 188).

By the same token, the nationalist, state-seeking ambition of national minorities isimperfectly captured, even trivialized, bythe notion of multicultural citizenship. Thevery case of Quebec, which partially moti-vated Kymlicka’s theory, demonstrates this.The Quebecois have always fiercelyrejected Canada’s multiculturalist policies,because Canada’s binational founding struc-ture is insufficiently visible in them. In fact,

Canadian official multiculturalist policy wasintroduced just two years after the OfficialLanguages Act of 1969 had made French thesecond official language of Canada, and itwas an obvious attempt to make this conces-sion to the francophone community accept-able to the country’s other minorities,the immigrants and the Aborigines. TheQuebecois understood this symmetrizing,levelling function of official multiculturalism,and refused to be considered just a minorityamong other minorities in a multiculturalCanada. It is astonishing that Kymlicka,who is perfectly aware of the stern aspira-tions of (some) national minorities, and whohas argued in particular that only an ‘asym-metrical’ understanding of Canadian federal-ism could accommodate Quebec (Kymlicka,1998: Ch. 10), has distorted the asymmetri-cal, monocultural pretensions of nationalminorities in the symmetrical and pluralistnotion of multicultural citizenship.

The pluralist thrust of multiculturalcitizenship is more plausible in the case ofimmigrants, the second legitimate claimantin Kymlicka’s scheme. In fact, all officialmulticulturalist policies, starting withCanada and Australia in the early 1970s,have prominently (though not exclusively)targeted immigrants. However, immigrantspose their own difficulties for Kymlicka’sscheme. In contrast to strong self-governmentrights for national minorities, immigrants aredue only more moderate ‘polyethnic rights’ –examples being exemptions from somegeneral laws that discriminate against minor-ity beliefs and practices, or special benefits(like support for ethnic organizations ormother-tongue instruction and services) thataccrue to the majority population automati-cally. However, qualifying these measures as‘rights’ is misleading, and it would be moreappropriate to call them contingent policies –even within Kymlicka’s scheme. Why? Thepurpose of minority rights is to secure accessfor minority groups to their own societalculture. However, immigrants, in voluntarilyleaving their country of origin, have ‘waived’the right to their culture (Kymlicka, 1995: 96).Accordingly, the thrust of ‘polyethnic

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rights’ is integration into the majorityculture. Kymlicka’s low-key stance onimmigrant rights is healthily realistic:3 nostate would continue admitting immigrantsif they arrived with the right to recreate theirhomelands; and immigrant groups are usu-ally ‘too small and dispersed’ to form viablesocietal cultures (Kymlicka and RubioMarin, 1999: 146). However, this realismcan be turned against the theory itself. Ifimmigrants have ‘waived’ the right to theirsocietal culture, there is no ground withinthis theory to endow them with any special‘right’ at all. To call those immigrantintegration policies of states that are morecontingent and public order-oriented thanrights-based an instance of ‘multiculturalcitizenship’ seems to be overstated, evenmisleading.

Most critics of Kymlicka’s theory ofmulticultural citizenship have zeroed inon its key concept of societal culture (e.g.Benhabib, 1999: 53–6). Joseph Carensrightly detects in its monolithic contours the‘old logic of the nation-state’ (2000: 66),making it ‘much better suited to a mono-cultural conception of citizenship than to amulticultural one’ (2000: 65). Most nationalminorities, particularly the decimated andbeaten ones, could never venture on thebuilding of an institutionally completenation-like culture, from schools to mediaand hospitals, leaving the basis of theirrights claims unclear; and for immigrants ‘itis not clear why (they) are entitled to anyspecial rights to maintain their distinctivecultural commitments’ (2000: 57). There isindeed a tension in Kymlicka’s concept ofculture between being either too thick or toothin: ‘too thick’ to give a realistic account ofthe relationship between liberal states andculture; ‘too thin’ to justify any minorityrights at all, particularly for immigrants. Letme develop both lines of criticism in turn.

On the one hand, states are axiomaticallypresented in Gellnerian terms as strong andtireless nation-builders, as guardians of athickly conceived majority culture, now asin the nineteenth century, the high point ofindustrialism and nation-building in the

West (Kymlicka, 1995: 76f.). This is not arealistic picture for contemporary liberalstates. Consider their treatment of immi-grants. If one takes the nationalizing practicesof states as variable rather than parameter,one sees that in contemporary liberal statesthere is very little that these states expect ofand impose on their newcomers, even at thepoint of acquiring citizenship. If this is thecase, it is not clear why these states shouldconcede minority rights in return for their (veryminimal) cultural impositions. Immigrantintegration policies are everywhere clothed inmulticultural rhetoric, shunning the ‘assimi-lation’ of immigrants (see Joppke andMorawska, forthcoming). Even in an extremecase of nation-building, like Quebec, the onlynationally distinct imposition is the require-ment to adopt French language in public life.The other integration requirement in Quebec’simmigrant policy is a dual commitment todemocracy and pluralism, which is notspecific to Quebec but generic to all liberaldemocracies (Carens, 2000: 113).

Language, in fact, boils down to the onesubstantive, and not just procedural, imposi-tion on immigrants. Partially in response toimmigration, liberal states have gone a longway toward tilting all (however implicit)ethnic preferencing in their policies andinstitutions – the shrill Foulard affair inFrance has been the exception to the gener-ally smooth and noiseless adaptation ofEuropean states to the Islamic religionimported by some of their immigrants (seeBauböck, forthcoming). Language is differ-ent, because the state has to rely on it in itsvery functioning – the state can distanceitself from religion (and it has actually doneso), but not from language. However, lan-guage differs from religion in that a personcan speak several languages, but can adhereto only one religion. This suggests that theidentitarian implications of language use areless than those for religious practice. Atleast it is not clear why the adoption ofanother language would deprive a person ofa meaningful context of choice.

The relaxing of liberal states’ nationalizingpractices is equally visible in the attribution

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of citizenship. While in international lawstates have the sovereignty to determinetheir nationality laws, a creeping rights-logic has rendered this a sovereignty onpaper only. This is especially visible inEurope, whose jus sanguinis tradition had atfirst erected high hurdles to citizenship forimmigrants. To better integrate their later-generation labor and postcolonial immigrants,most European states have in the meantimeadded jus soli elements to their blood-centered nationality laws. With the exceptionof Luxembourg, Greece, and Austria, allmember states of the European Union nowprovide a right to citizenship to their second-and third-generation immigrants (see theoverview in Weil and Hansen, 1999). Inaddition, most European states have signifi-cantly lowered the requirements for naturaliza-tion. Germany, for instance, which was untilits recent citizenship reform the proverbiallyethnic state, in the early 1990s introducednon-discretionary as-of-right naturalizationfor later-generation immigrants of legalresidence and in effect no longer requiredthese citizenship applicants to be culturallyassimilated (Joppke, 2000).

These recent changes of immigrant inte-gration policies and nationality laws inliberal states have important implications formulticultural citizenship: if minority rightsare compensation for states’ strong nationali-zing practices, the weakening of thesenationalizing practices removes the case for(this type of) minority rights.

On the other hand, in response toWaldron’s ‘cosmopolitan’ alternative multi-culturalism (Waldron, 1992), Kymlicka hasadmitted to a rather ‘thin’ picture of societalcultures in modernized societies. Citing thecase of modern Quebec, Kymlicka finds thatall have a place in it, ‘e.g. atheists and Catholics,gays and heterosexuals, urban yuppies andrural farmers, socialists and conservatives,etc.’ (Kymlicka, 1995: 87). In fact, to beQuebecois today ‘simply means being a par-ticipant in the francophone society of Quebec’(ibid) – this indicates again the unique posi-tion of language in the contemporary liberalstate’s cultural impositions. If this is the case,

it is not clear why the state’s inherentalignment with this thin and pluralistic culture,which excludes virtually no one, should neces-sitate compensatory minority rights.

MULTICULTURAL CITIZENSHIPIN PRACTICE

Whatever the difficulties of justifying multi-cultural citizenship at the theoretical level,does it exist anywhere in the real world?Here it is important to distinguish betweenexplicit multicultural citizenship, in whichthe latter is an official state program, andimplicit multicultural citizenship, in whichdiversity claims have widely diffused with-out being written on the forehead of the stateconcerned. Explicit multicultural citizenshipcan be found in less than a handful ofWestern states. The most prominent exam-ples are Canada and Australia, where thevery notion of multiculturalism originated inthe early 1970s. Canada made a start in 1971with its policy of ‘multiculturalism within abilingual framework’ (quoted in Kymlicka,1998: 55). As indicated above, this multi-culturalism is compensation for accommo-dating the francophone national minorityof Quebec, and thus rather separate fromthe concerns of the latter. Interestingly,its underlying concern is not so much minor-ity recognition as state neutrality, or, inKymlicka’s terms (1998: 57), ‘(to) separatethe … dominance of … common languages …from the historical privileging of the interestsor lifestyles of the people descended fromthe historically dominant groups.’ In linewith this de-ethnicizing function, Canadianmulticulturalism is an integrative offer forthe whole society, not just for minorities.This is explicit in the Canadian Multicultural-ism Act of 1988, which ‘acknowledges thefreedom of all members of Canadian societyto preserve, enhance and share their culturalheritage’ (quoted in Kymlicka, 1998: 185;emphasis added).

The nation-building function of multi-culturalism is even more visible in Australia.

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One of its central documents, the NationalAgenda for a Multicultural Australia, passedby a Labour government in 1989, stressesthat multiculturalism is a ‘policy for manag-ing the consequences of cultural diversity inthe interests of the individual and society asa whole’ (quoted in Castles and Davidson,2000: 166; emphasis added). More than itsCanadian precursor, Australian multicultural-ism stresses the limits of diversity: ‘Multi-cultural policies are based on the premisethat all Australians should have an over-riding and unifying commitment to Australia,to its interests and future first and foremost’(quoted from the National Agenda, in Castlesand Davidson, 2000).

Canadian and Australian multiculturalistpolicies have gone along with a liberalizationof citizenship laws, which had previouslybeen tainted by racial selectivity. TheAustralian Citizenship Act of 1973, forinstance, considerably lowered the residenceand language requirements for naturalization,and no longer asks for a ‘transfer of culturalattachments,’ only for a procedural commit-ment to liberal democratic values (Castles andDavidson, 2000: 168). Castles and Davidsontherefore conclude that ‘Australia’s citizen-ship rules are now multicultural rather thannational’ (2000: 169). More correct would beto say that multicultural citizenship in Australia(as well as in Canada) is a distinct way ofconceiving of national citizenship.

The few explicitly multiculturalist poli-cies in Europe, notably those of Sweden andthe Netherlands, look rather different. Theyare not identity options for society as awhole, but target immigrants only. In thissense, they are closer to ‘multiculturalcitizenship’ in Kymlicka’s sense. However,it is also misleading to couch Europeanmulticulturalism policies in the language ofcitizenship, because one of their initialpurposes was to protect the status of immi-grants qua aliens and not to impose on themthe citizenship of the receiving state.

It is worth referring here to the rathercurious Swedish experience. A key purposeof Sweden’s multicultural Immigrant andMinority Policy launched in 1975 was to

give immigrants the ‘freedom of choice’between maintaining their ethnic identity oradopting a (obviously ethnically conceived)Swedish identity (see Wieviorka, 1998:686). This implied that immigrants wouldnot be forced into Swedish citizenship(though citizenship was easier to acquire inSweden than in most other countries ofEurope). Expressions of the upgrading ofalien status were the introduction of localand regional voting rights for immigrants in1975, and – most important – the inclusionof a clause on ethnic and linguistic minorityprotection in the Swedish constitution in1976. However, a parliamentary inquiry inthe early 1980s correctly noted that in inter-national law only autochthonous minorities –that is, long-settled, territorially concentratedminorities with citizenship status – wereentitled to minority protection. In addition,the inquiry suggested that the proper mean-ing of ‘freedom of choice’ could not be thestate’s active furthering of ethnic minorityidentities, but its adopting a ‘neutralposition’ and desisting from forced culturalassimilation (Soininen, 1999: 690). Thegovernment heeded this advice, renamingits ‘immigrant and minority policy’ ‘immi-grant policy.’ This was but a step in Sweden’sgradual withdrawal from its explicitlymulticulturalist policy. In the 1990s, esca-lating unemployment among immigrantsmoved the attention from cultural to econo-mic issues. The multicultural society was nolonger a desirable project for the future butan unavoidable reality that had to be masteredby a centrist rather than difference-orientedstate policy. Now the Swedish governmenteven tilted the ‘immigrant’ reference fromits immigrant-related policy, calling the lattersimply ‘integration policy’. Its stress is nolonger to protect immigrants as ethnicgroups, but to enable them as individuals to‘acquire the Swedish tools which can beneeded to manage on one’s own in Swedishsociety’ (a government statement of 1995,quoted in Soininen, 1999: 692).

The Dutch withdrawal from explicitmulticulturalism has been even moreextreme (see Entzinger, 1999). The Dutch

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Minderhedennota (ethnic minorities policy)of 1983 earmarked eight official immigrantminorities for ‘emancipation,’ not withinDutch society, but within state-supportedethnic parallel societies, reminiscent of the‘pillar’ tradition in this religiously and ideo-logically divided country (see Lijphart,1968). This most multicultural of allEuropean immigrant policies soon ran intoproblems. First, the ethnic diversificationof migrant streams in the age of asylum-seeking made it simply impracticable toprovide each ethnic group with its own infra-structure, including ethnic schools, media,and social services. Second, the focus on cul-tural autonomy proved inadequate for themost pressing problem facing immigrants:unemployment and socioeconomic margin-alization. In response, much as in Sweden,there has been a reorientation toward‘open[ing] up the existing institutionalarrangements to immigrants, rather than aim-ing at the development of new, parallel insti-tutions’ (Entzinger, 1999: 10). All referencesto ethnic minorities, even the very notion ofimmigrant, were erased from the state’s new‘integration policy,’ and the new emphasiswas on integrating newcomers as individualsrather than as members of groups. The Dutchwithdrawal from explicit multiculturalismculminated in the 1998 Law on the CivicIntegration of Newcomers, which requiresnew (non-EU) immigrants to take 600 hoursof civics and Dutch language classes.

The demise of official multiculturalistpolicies in Europe is not the result of aright-wing backlash. As in the Netherlands,impeccable liberals have driven the change.4

The insight took hold that it was counterpro-ductive to fuel the centrifugal thrust of ethni-cally diversifying societies with explicitlymulticulturalist policies. This implies afundamental re-evaluation of multiculturalism,which is no longer seen as a normativegoal but as an empirical exit-condition ofstate policy.

In contrast to the precarious nature ofexplicitly multiculturalist policies, implicitmulticulturalism is deeply entrenchedthroughout immigrant-receiving Western

states. It reflects the simple fact that liberalstates cannot but sit on top of pluralizingsocieties. A good example of this is theUnited States. Unlike the other new settlernations, (Canada and Australia), the UnitedStates does not officially consider itself amulticultural society. Nathan Glazer, whocaptured the pervasive reality of Americanmulticulturalism in the happy notion that ‘weare all multiculturalists now’ (1997), alsopointed to the fact that there was ‘nothingmulticultural yet’ about US naturalizationlaw, which requires citizenship applicants toswear an oath of allegiance to their newcountry (Glazer, 1999: 196). Unlike Canadaand Australia, which are still today part ofthe British Commonwealth, the UnitedStates has its own founding myth, one thatinvites ethnic pluralism through its exclu-sively political content, but also checks suchpluralism through its very existence. Therecent ‘Americanization’ campaign of thefederal government invokes this distinctfounding myth of ‘liberty, democracy andequal opportunity’ (US Commission onImmigration Reform, 1997: 26),5 which isnot available in Canada or Australia, andsubstituted there by their post-British nation-building commitment to multiculturalism.

American multiculturalism rests on thedual pillars of affirmative action and publiceducation (see Joppke, 1999: Ch. 5). Affir-mative action is an example of the ‘specialrepresentation rights’ identified by Kymlicka(1995: 31–3) as an intermediate, third cate-gory of minority rights. Its purpose (thoughnot its reality) is to be temporary only, andto redress discrimination on the basis of race(as well as sex and other ascriptive markers,such as, more recently, physical handicaps).However the state has not carved outofficial racial categories in order to givethem public recognition; rather, racial cate-gorizing is an unintended consequence ofanti-discrimination laws and policies, origi-nally color-blind, that were driven towardscolor-consciousness by concerns of admini-strative efficiency (see Skrentny, 1996).Accordingly, classifying affirmative actionas an instance of multicultural citizenship

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may appear to be stretching the meaning ofthe term, if the latter is meant to be recogni-tion and protection of minority cultures.However, affirmative action is a policy withmany faces (see Skrentny, 1998). One ofthem is the quintessentially multiculturalidea of mirror representation, which seessociety as a composite of ‘groups’ and callsfor their proportional representation in keysectors such as the polity, higher education,and the workplace (on the idea of mirrorrepresentation, see Phillips 1995).

The main site of American multicultural-ism is the ‘world of education’ (Taylor, 1992:65), where it has appeared as the claim fornon-Western-centered public school andcollege curricula. If minority cultures havefound public recognition in the USA, it ismostly through their successful entry intothe curriculum – up to a point, as CharlesTaylor critically remarks, where the ‘pre-sumption’ of the equal value of the creativeexpressions of minority cultures is replacedby the ‘peremptory demand for favorablejudgments of worth’ (Taylor, 1992: 71).This has been exhaustively discussed underthe rubrics of ‘culture wars,’ ‘politicalcorrectness,’ etc. It is more interesting forour purposes that this form of multiculturalcitizenship is thoroughly entrenched yet hasremained short of official state recognition –also because in the federal US polity theresponsibility for public education is multi-ply divided, horizontally between publicand private actors and organizations, andvertically between the federal, state, andsubstate levels.

The American case points to a centralshortcoming of the idea of multiculturalcitizenship: its fixation on the state. Thisfixation is perhaps unavoidable becausecitizenship refers to a relationship betweenthe individual and the state. However, it hasobscured the multiple entry points of multi-cultural claims in the fabric of functionallydifferentiated societies. To catch the perva-sive reality of implicit multiculturalism, wehave to change the root image of modernsociety: not (exclusively) bounded andsteered from the top or by a state, but (also)

composed of a multiplicity of autonomoussubsystems. Among the latter the politicalsystem is only one, and not one that couldclaim to be more central than the others – inLuhmann’s diction, modern societies have‘neither peak nor center’ (1986: 167–182).

One important sphere in which implicitmulticulturalism has quickly taken hold ismarkets. Because of the ‘Hispanic market,’Spanish has established itself as the unoffi-cial second language in certain (southwesternand southeastern) parts of the United States –automatic bank tellers in California givecustomers the choice of English or Spanish;large billboards on Los Angeles’ glamorousWilshire Boulevard advertise their productsin Spanish; the leading newspapers in LosAngeles and Miami now publish Spanish-language editions. An advertisement in thebusiness section of the New York Times hasthe obvious answer to the question, ‘WhyHispanic?’: ‘Because in the next 15 yearsHispanic buying power in New York willdouble to $89.9 billion dollars!’ (quoted inZolberg and Woon, 1999: 37, fn.74). AsZolberg and Woon (1999: 26) concludetheir important observations, there is now a‘market-driven multiculturalism’ in the USA,‘quite independently of any public policychoices.’

A second sphere in which implicit multi-culturalism has found entry is the legalsystem. A staple in multicultural-citizenshipreasoning is that the individual-rightsprinciple of non-discrimination is notenough to protect minorities.6 Thisunderestimates the teeth of this legal prin-ciple. In Europe, for example, general con-stitutional provisions on family rights andreligious freedoms have been sufficient toexempt a particularly vulnerable group,Muslim girls, from parts of the public-school curriculum that their parents deemincompatible with Islamic norms (seeAlbers, 1994). In Germany, a landmark deci-sion by the Federal Administrative Court inearly 2000 forced the Senate of Berlin torecognize an Islamic sect (Milli Görüs) as anofficial religious organization, with the rightto teach Islam in Berlin’s public schools. Not

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explicit minority rights, but universal legalprinciples seem to be sufficient to put Islamon the path to establishing itself as the fourthofficial religion in Germany.7

Sometimes multicultural recognitionclaims are not only indirectly satisfied bythe law’s individual non-discriminationprinciple, but have come to shape legalstrategies and principles directly. An exam-ple of the latter is the recent ‘culturaldefense’ strategy in American criminal law(see Coleman, 1996). It builds on a long-standing trend in American criminal lawtoward ‘individualized justice.’ Departingfrom the previous principle that everyoffense in a like legal category calls foridentical punishment, individualized justicetakes into account mitigating circumstancesand the individual character and propensi-ties of the offender in the assessment of guiltand punishment. Cultural defense injects thedefendant’s culture as one such mitigatingand individualizing circumstance into thecriminal process. It argues that someoneraised in a foreign culture should not be heldfully accountable for conduct that violatesdomestic law if that conduct would beacceptable under his or her native law.Successfully invoked by immigrant defen-dants in California, New York, Georgia andMinnesota, the cultural defense strategy hasled some courts to reinterprete rape amongHmong refugees as part of their traditionalcourtship customs; to consider wife-beatingand killing among Chinese as conditionedby ‘traditional Chinese values about adul-tery and loss of manhood’ (quoted inColeman, 1996: 1109); and to exoneratefrom manslaughter charges a Japanesemother who had drowned her three childrenbecause in Japanese culture mother-childsuicide is an accepted method for betrayedwives to escape shame. As Coleman pointsout, there is a tension between culturaldefense and individualized justice, becausein the former the question of moral culpabil-ity is not answered by resort to the particu-lar individual’s beliefs, but by summarilyinvoking his or her subgroup’s culturalstandards (1996: 1126f).

More disturbingly, this ‘clearest exampleof how multiculturalism has influenced thelaw’ (Coleman, 1996: 1100) violates theequal protection doctrine and anti-discrimi-nation principle, the cornerstones of UScivil rights law, because it denies justice tothe immigrant women and children harmedby immigrant offenders. Multicultural crim-inal law thus poses a ‘Liberals’ Dilemma’(1996: 1096): the liberal impulse in criminallaw to protect the offender (see Dworkin,1978: 135f.) leaves unprotected the victimsof immigrant crimes. Moreover, the liberal’smulticultural defense of the immigrantoffender ‘re-institutes a bifurcated criminalcode that is frighteningly similar to the oldslave codes and to the black codes thatbriefly existed after the Civil War’ (Coleman,1996: 1144) – to undo what had been wholepoint of the 14th Amendment’s equal protec-tion clause.

The example of multicultural criminallaw raises a larger problem for advocatesmulticultural citizenship: the question ofhow to deal with illiberal minority cultures.Feminist authors in particular have pointedto the fact that endorsing (very often chau-vinist and authoritarian) minority culturesmay amount to the suppression of womenand internal dissidents (e.g. Shachar, 1999).This is a very serious charge that, in myview, has not been convincingly rebutted bydefenders of multicultural citizenship.8

Kymlicka (1995: Ch. 8) distinguishes in thiscontext between minority rights as ‘externalprotections’ (which secure equality betweenminority and majority groups in society andare therefore legitimate from a liberal pointof view) and minority rights as ‘internalrestrictions’ (which suppress the autonomyof the members of minority groups andtherefore cannot be endorsed by a liberal).Building his theory of minority rights on theprinciple of individual autonomy (ratherthan toleration) allows Kymlicka to be morecritical of illiberal minority groups thansome liberals who reject group rights butallow for internal restrictions in the name oftoleration (e.g. Kukathas 1992). However,the liberal theorist’s rejection of minority

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rights that restrict the autonomy of minorityindividuals does not mean, according toKymlicka (1995: 171), that liberals canimpose their principles on illiberal groups:‘Liberals have no automatic right to imposetheir views on non-liberal national minori-ties.’ Much as in the world of interstaterelations, where the principle of non-intervention is firmly established, all thatliberals can hope for in their dealings withilliberal national minorities is the soft powerof ‘dialogue’ – in a word, much as we mightdespise illiberal minority practices, we haveto let them go. Note, however, that this hands-off approach may be relaxed in the case ofvoluntary immigrants, where ‘it is more legiti-mate to compel respect for liberal principles’(Kymlicka, 1995: 170) – only, ‘how’ legiti-mate this is and where the margin of thetolerable ends even this most succinct accountof the limits of toleration does not say.

CONCLUSION

Where does this discussion of the theory andpractice of multicultural citizenship leaveus? At the level of theory, attempts to groundminority rights in ‘oppression’ (Young,1989) and ‘societal culture’ (Kymlicka,1995) have run into difficulties. With thevague concept of ‘oppression,’ all of societyis turned into a composite of minorities, in akind of apartheid in reverse. The more con-cise concept of ‘societal culture’ prudentlynarrows the range of legitimate multiculturalclaimants, one of which, however, sees itsmonocultural, nationalist ambitions trivial-ized and distorted by the pluralist notion ofmulticultural citizenship (national minori-ties), while the other’s rights claims are leftwithout a basis (immigrants).

Kymlicka’s liberal theory has the advan-tage over Young’s radical theory of beingmore closely aligned with actual state prac-tices regarding minorities – no abstract prin-ciples are held against states from theoutside, but liberal states are confrontedwith the normative implications of some of

their own time-tested practices regardingminorities. However, the central shortcom-ing of Kymlicka’s theory is its exclusivefocus on the internal rights dimension,disregarding as an unchangeable parameterthe external state-membership dimension ofcitizenship. If the argument is that axiomati-cally assumed strong nationalizing practiceson the external citizenship dimension justifyminority rights, this nexus is empiricallyrendered obsolete by the trend towardde-ethnicization in liberal states. Particularlyin response to immigration, liberal states haveexcised most ethnic references from theircitizenship laws and integration policies – itis de rigueur in all of them not to ‘assimilate’immigrants, even at the point of citizenshipacquisition. As liberal states, in response toethnically diversifying societies, are busilytilting all ethnic majority preferencing andreferencing, it would be strange to demandthat they reverse this trend for ethnic minori-ties (except in the rare and serious cases ofstate-seeking national minorities).

Michael Walzer (1992: 100f.), in astridently liberal rejection of multicultural-ism, has drawn a distinction between theethnically neutral American ‘nation of nation-alities,’ where ‘there is no privileged majorityand there are no exceptional minorities,’ andthe ethnic ‘nation-states’ of Europe, whose‘governments take an interest in the culturalsurvival of the majority nation.’ Since stateneutrality is realized in the United States,there is no point in granting minority rightshere; in the ethnic states of Europe, accord-ing to Walzer, minority rights are moreappropriate, even though these states mayfind such rights impracticable. Walzer isboth right and wrong: right in his intuitionthat liberal states can (and do) live up to theideal of neutrality, thus rendering the idea ofminority rights pointless; but wrong in hisbelief that striving for public neutrality is aprivilege of the United States. The UnitedStates is not different in kind from Europeanstates. All European immigrant-receivingstates are moving in the same, Americandirection of politically constituted nation-hood and territorial citizenship.

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The trend towards state neutrality also inEurope is perhaps best documented in therecent controversy in Germany over a‘deutsche Leitkultur’ (German dominantculture) that immigrants should adopt. Thenotion was introduced by the conservativeopposition party in parliament (CDU), as anantidote to Germany’s current openingtoward new labor migration. Interestingly,when pressed to define it, its proponentscould not say what exactly the deutscheLeitkultur was. For the CDU parliamentaryleader, it consisted of the ‘constitutional tra-dition of our Basic Law,’ the ‘Europeanidea,’ equality of women, and the Germanlanguage – in that order, with the onlyspecifically ‘German’ marker appearinglast, and overlapping with the functionallanguage requirement.9 This was also pre-cisely how the SPD Chancellor, like most inthe political élite an opponent of the notionof Leitkultur, defined the criteria of immi-grant integration.10 A CDU position paperon immigration, notable also for the party’sretreat from its long-held mantra thatGermany was ‘not a country of immigra-tion,’ finally included the contested notionof Leitkultur.11 It identifies as ‘Christian-occidental culture’ the value added byLeitkultur to the constitutional and languageobligations that are agreed by all. However,this ‘culture’ is already circularly interwovenwith Germany’s laws and constitution, and –most disturbingly – it does not contain any-thing that is particularly ‘German’: everycountry in Europe, and many countriesbeyond Europe too, share this ‘culture.’

David Miller, philosophical proponent ofliberal nationalism, defined national iden-tity, among other things, as a ‘distinct publicculture’ (1995: 27), which is meant to bemore than the ‘common currency of liberaldemocracies,’ because it provides an answerto the question ‘why the boundaries of thepolitical community should fall here ratherthan there’ (1995: 163). Germany’s incon-clusive wrangling over Leitkultur shows thata liberal state cannot formally commit itsimmigrants to anything that exceeds the

procedural canon of liberal democratic rules.This creates the paradox that the politicalcommunity that immigrants are to be social-ized into has to remain unnamed. And, forour purposes, it leaves unclear what exactly‘multicultural citizenship’ is supposed toremedy.

At the level of practice, multiculturalcitizenship as written on the forehead of thestate has remained exceedingly rare. As thefew European states that once practicedmulticultural policies (though not: multicul-tural citizenship policies) are moving awayfrom them, perhaps only Canada and Aus-tralia qualify – though their multiculturalcitizenship differs from that of the theoristby being a citizenship for all, not just forminorities. At the same time, the state-centered ‘top-down’ notion of multiculturalcitizenship has deflected from the multiple‘bottom-up’ successes of multiculturalclaims in the decentered subsystems ofdifferentiated societies, which haveremained short of official state recognition.Considering that multiculturalism is de factoeverywhere in liberal societies, whereas it isexplicit policy only in some countries (andfor some groups therein), it may be better touse a diverse vocabulary to capture a diversereality – and not to swallow the latter underthe general and in important respects mis-leading rubric of ‘multicultural citizenship.’

NOTES

This chapter was first published as ‘MulticulturalCitizenship: A Critique’ in Archives européennes desociologie (May 2001). It is reprinted here with the kindpermission of Cambridge University Press.

1 Young (1990: Ch. 2) lists ‘five faces of oppression’:exploitation, marginalization, powerlessness, culturalimperialism, and violence.

2 A better but metacritical attempt is Offe (1998).3 See, by contrast, Parekh’s (1994) stronger claim that

immigrants, as ‘probationary citizens’, have a ‘moralright’ to preserve their difference.

4 The liberal sociologist Han Entzinger mastermindedthe 1998 Dutch Law on Civic Integration.

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5 ‘The Commission reiterates its call for theAmericanization of new immigrants, that is the cultivationof a shared commitment to the American values of liberty,democracy and equal opportunity’ (US Commission onImmigration Reform, 1997: 26).

6 See Kymlicka’s critique of ‘benign neglect’ (1995: 3f).7 See ‘Das Recht auf Unterricht’, Die Zeit, 2 March

2000: 32.8 A sensible contextual approach to ‘the limitations of

liberal toleration’ is given by Carens (2000: Ch. 6).9 Friedrich Merz (CDU), in Die Welt, 25 October 2000.10 Gerhard Shröder (SPD), in Frankfurter Allgemeine

Zeitung, 6 November 2000: 1.11 Arbeitsgrundlage für die Zuwanderungs-Kommis-

sion der CDU Deutschlands, 6 November 2000, Berlin(http://www.cdu.de).

ACKNOWLEDGEMENT

The text of the above article has been previouslyprinted in the European Journal of Sociology, XLII(2001), 431–447. Reprinted with permission.

REFERENCES

Albers, Hartmut (1994) ‘Glaubensfreiheit und schulischeIntegration von Ausländerkindern’, Deutsches Verwal-tungsblatt, 1 September, pp. 984–90.

Bauböck, Rainer (forthcoming). ‘Cultural Minority Rightsin Public Education’, in A. Messina (ed.), Europe: TheNew Melting Pot? Boulder: Westview Press.

Benhabib, Sheila (1999) ‘ “Nous et les autres” ’ inC. Joppke and S. Lukes, (eds), Multicultural Questions.Oxford: Oxford University Press.

Brubaker, Rogers (1992) Citizenship and Nationhood inFrance and Germany. Cambridge: Harvard UniversityPress.

Carens, Joseph (2000) Culture, Citizenship, and Commu-nity. Oxford: Oxford University Press.

Castles, Stephen and Davidson, Alastair (2000) Citizen-ship and Migration. Basingstoke: Macmillan.

Coleman, Doriane Lambelet (1996) ‘IndividualizingJustice Through Multiculturalism’, Columbia LawReview, 96 (5): 1093–1167.

Dworkin, Ronald (1978) ‘Liberalism’, in Stuart Hampshire(ed.), Public and Private Morality. Cambridge:Cambridge University Press.

Entzinger, Han (1999) ‘Towards a Model of Incorpora-tion: The Case of the Netherlands’, unpublishedmanuscript.

Glazer, Nathan (1997) We Are All Multiculturalists Now,Cambridge: Harvard University Press.

Glazer, Nathan (1999) ‘Multiculturalism and AmericanExceptionalism’, in C. Joppke and S. Lukes (eds), Mul-ticultural Questions. Oxford: Oxford University Press.

Joppke, Christian (1999) Immigration and the Nation-State: The United States, Germany, and Great Britain.Oxford: Oxford University Press.

Joppke, Christian (2000) ‘Mobilization of Culture and theReform of Citizenship Law’, in R. Koopmans andP. Statham (eds), Challenging Immigration and EthnicRelations Politics. Oxford: Oxford University Press.

Joppke, Christian and Ewa Morawska (eds) (forthcoming)Toward Assimilation and Citizenship. Basingstoke:Palgrave.

Kukathas, Chandran (1992) ‘Are There Any CulturalRights?’, Political Theory. 20 (1): 105–39.

Kymlicka, Will (1995) Multicultural Citizenship. Oxford:Oxford University Press.

Kymlicka, Will (1998) Finding Our Way. Toronto:Oxford University Press.

Kymlicka, Will and Rubio Marin, Ruth (1999) ‘Liberal-ism and Minority Rights: An Interview’, Ratio Juris,12 (2): 133–52.

Lijphart, Arend (1968) The Politics of Accommodation.Berkeley: University of California Press.

Luhmann, Niklas (1986) Ökologische Kommunikation.Opladen: Westdeutscher Verlag.

Miller, David (1995) On Nationality. Oxford: ClarendonPress.

Offe, Claus (1998) ‘“Homogeneity” and ConstitutionalDemocracy’, Journal of Political Philosophy, 6 (2):113–41.

Parekh, Bhikhu (1994) ‘Cultural Pluralism and the Limitsof Diversity’, Alternatives, 20 (3): 431–57.

Phillips, Anne (1995) The Politics of Presence. Oxford:Oxford University Press.

Shachar, Ayelet (1999) ‘The Paradox of MulticulturalVulnerability’, in C. Joppke and S. Lukes (eds), Multi-cultural Questions. Oxford: Oxford University Press.

Skrentny, John (1996) The Ironies of Affirmative Action.Chicago: University of Chicago Press.

Skrentny, John (1998) ‘Affirmative Action’, AmericanBehavioral Scientist, 41 (7): 877–85.

Soininen, Maritta (1999) ‘The “Swedish Model” as anInstitutional Framework for Immigrant MembershipRights’, Journal of Ethnic and Migration Studies,25 (4): 685–702.

Taylor, Charles (1992) Multiculturalism and ‘The Politicsof Recogniton’. Princeton: Princeton University Press.

US Commission on Immigration Reform (1997) Becom-ing an American. Washington, DC: GovernmentPrinting Office.

Waldron, Jeremy (1992) ‘Minority Cultures and theCosmopolitan Alternative’, University of MichiganJournal of Law Reform, 25 (3&4): 751–93.

Multicultural Citizenship 257

sisin15.qxd 7/17/02 4:18 PM Page 257

Walzer, Michael (1992) ‘Comment’, in Charles Taylor

Multiculturalism and ‘The Politics of Recognition’.

Princeton: Princeton University Press.Weil, Patrick (2001) ‘Access to Citizenship’, in

T.A. Aleinikoff and D. Klusmeyer (eds), Citizenship:Comparisons and Perspectives. Washington, DC: TheBrookings Institution.

Weil, Patrick and Hansen, Randall (eds) (1999) Nationalitéet citoyenneté en Europe. Paris: La Decouverte.

Wieviorka, Michel. (1998) ‘Is Multiculturalism theSolution?’, Ethnic and Racial Studies, 21 (5): 881–910.

Young, Iris Marion (1989) ‘Polity and Group Difference:A Critique of the Ideal of Universal Citizenship’,Ethics, 99: 250–74.

Young, Iris Marion (1990) Justice and the Politics ofDifference. Princeton: Princeton University Press.

Zolberg, Aristide and Long Litt Woon (1999) ‘Why Islamis Like Spanish’, Politics and Society, 27 (1): 5–38.

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