Citizenship and Nationality in Democratic Systems: Approaches to Defining and Acquiring Membership in the Political Community

Abstract

This article analyzes the approaches of five democratic countries—France, the United States, Germany, Great Britain, and Israel—to determining membership in the national community. It examines the different definitions of citizenship and the variable uses of ascriptive and functional criteria, the mix of interpretations of jus sanguinis and jus soli, and the evolution of policies of naturalization. It deals with the circumstances surrounding the building of nation and state as explanatory factors, and discusses the implications of transnational and supranational patterns of socioeconomic involvements and entitlements for traditional approaches to citizenship.