Martin A.

Schain Managing Difference: Immigrant integration Poiicy in France, Britain, and the United States

IN

2004,

ARISTIDE

ZOLBERG DEVELOPED AN APPROACH TO

understanding immigrant integration that relates past experience, policies, and institutions to the present democratic management of cultural differences. Diversity, and diverse populations, he argues, is hardly a new phenomenon. Indeed, contrary to re-writings of history that represent cultural diversity as a departure from the norm, in reality heterogeneity was the more usual state of affairs. What has changed is the pattern of the management of diversity, and the relationship of these patterns to past experience. A distinctive feature of today's situation is that the differences are emerging under social and political conditions that render some of the older responses unfeasihle, either because they are impractical or because they are ruled out by the receivers' institutionalized obligation to respect human rights. . . . In this perspective, past experiences of diversity are relevant . . . as acceptance of diversity as a "fact of life" will contribute to the reduction of social tensions and the pohtical extremism they feed. . . . Moreover, management of the old differences generated

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dynamics that still play an important part in the political life of their societies (Zolberg 2004:1-2). In this paper I will compare changes in immigrant integration policies in two European countries—France and Britain—^with those of the United States. I vdll focus first on the "national models" around which integration policies have been described, and then on the dynamics that are driving the changes and evolution of these models. I argue that national models in each country differentiate the direction, the content, and the intensity of integration policy. These differences are most evident, moreover, if we examine not only the policies themselves, but the perceived success and failure of different integration policies. I argue that three dynamics have been driving the evolving management of integration policy: problems of urban order, the development of European Union, and perceptions of failure and success. UNDERSTANDING NATIONAL MODELS Scholars have frequently compared various "models" of incorporation as if most countries have well-thought-out policies based on either national traditions or reasoned strategies for "making" foreigners into Frenchmen, Britons, or Americans. The countries that are the subjects of this paper appear to be committed to very different ways of integrating immigrant populations that vary by the use of state institutions, the kinds of policies pursued (indeed, whether or not they actually have explicit policies of integration), and the assumptions behind these policies. They also vary in terms of what they expect integration to mean, what should emerge at the end of the process.^ Finally, they appear to vary in terms of what has emerged through the process of integration. Although pubhc philosophies are often clear on objectives, they neglect other kinds of realities. First, in each of these countries, actual public policy (as opposed to policy goals) that deals directly vwth integration is limited, and often contradictory. There is often a wide gap between stated public philosophies and policy on the ground. These understandings of integration models, moreover, often ignore the

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evolution over time of both public philosophy and public policy rooted in this philosophy. If this is true, a question remains whether the concept of public philosophy has any meaning at all, apart from political rhetoric. I v^^ould argue that it does, as long as we can demonstrate empirically that "its principles continue to inspire government policy towards immigrants," and to alter the rhetoric would in itself "weaken (and perhaps even dissolve) the social fabric" (Schnapper 1994:133-135). MANAGING DIFFERENCE: FRANCE The best defined process of integration seems to be the French Republican model, which has become more explicit in detail as its assumptions have been challenged by the most recent waves of immigration from North Africa. In principle, the French model recognizes the legitimacy of collective identities only outside the public sphere. This has come to mean that ethnic and religious groups are accorded no special privileges in public policy, nor are they granted special protection. This also means that there is "color-blind" public support and recognition only for individual merit and individual advancement (Noiriel 1988:189-245; Long 1988: 82-105). The first indication of the complexity within the French Republican model can be seen at the local level, as political parties attempted to integrate the post-World War I wave of European immigrants. Between the wars, among the most powerful instruments for integrating new immigrant populations were the trade union movement and the French Communist Party, both of which sought new members (and eventually electoral support) by mobilizing workers from Poland, Italy, and after the Second World War, workers from Spain. Part of their effort certainly focused on class solidarity, but mobilization was also based on ethnic and religious solidarities (Withol de Wenden 1988: 50). The establishment of communism in immigrant communities eventually destabilized older political patterns in these same areas, but at the price of the establishment of local ethnic machines, many of which endured well into the Fifth Republic (Schain 1994).

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and the emphasis on race has probed the limits of the integrative capacities of the French version of the melting pot. As during the earlier period. Nevertheless. Even when established and more universal intermediary groups. and the state at the local and national levels (Wihtol de Wenden 1992). unique to towns governed by Communists (Grillo 1985:125-127. did succeed in incorporating their leadership. but now in an exclusionary manner. Barou 1994: 24).Wefinda similar pattern with the wave of Third World immigration after 1960. By the mid-1980s. the most important of which is that the pattern of policymaking has been conditioned by what Maxim Silverman has termed the "racialized" view of the post-1960s wave of nonEuropean immigrants in a way that has clearly differentiated them ñ-om the waves of European immigrants that preceded them (Silverman 1992. In contrast to earlier periods of immigration. Studies on the ground provide clear evidence of the recognition of immigrant collectivities by both political parties and public authorities. these associations operated largely outside the established network of intermediary groups. such incorporation remained conditional and problematic (Schain 1994b) Multiculturalism and Urban Order But how can we understand this evolution of policy on the ground? Perhaps the best explanation is that the French state has focused on 208 social research . however. This pattern was not. such as trade unions. In contrast to the tradition of positive sohdarity that Communistgoverned municipalities had developed toward predominantly European immigrants. 4). Perhaps the most important change was the growth of ethnic associations after legislation legalizing them was passed in 1981. which were then forced to recognize their independent existence. chap. political parties. these associations had become a network of established intermediaries for immigrant populations that negotiated with trade unions. there are some differences. by the 1970s many of these same local governments began to treat non-European immigrants as temporary residents who must be encouraged to return home (Schain 1985). Communist municipahties tended to treat new immigrant communities as collectivities.

rather than populations.2 This has meant that relatively narrow geographic criteria have taken the place of group criteria." both local governments and the central state sought out and sometimes supported whatever ethnic associations they felt could maintain social order. and issued its first report in May 2006. In education. 45 percent of them complaints of employment discrimination. Council Directive 2003b). problems of rising dropout rates and student failures among the children of immigrants resulted in the establishment of several programs. and its efforts contributed to the development of ethnic organization as state agencies engaged in a sometimes desperate search for intermediaries among what became known as the "second generation" (Body-Gendrot 1993.multicultural policies as it has given greater attention to issues of domestic security. France has moved in this direction.000 complaints from individuals. were made necessary by the restrictions imposed by the Republican model. The Public Philosophy Looking back over the last 25 years of French policy on integration. 5 and 6. the Republican model had molded the way that groups are targeted. it received more than 2. various approaches to discrimination have become integral to policy on integration since 2000. Managing Difference 209 . Clumsy rules that targeted geographic areas. In this way. and a 1978 law dealing with information. the most important of which was the zones of educational priority (ZEP) (Caron 1990). In fact. the involvement of the state grew. As periodic urban riots that started in the early 1980s continued over more than two decades. Jazouli 1992). that there has been a greater volume of policy. In a sometimes desperate search for interlocuteurs valables among the "second generation. The High Authority against Discrimination and for Equality (HALDE) was established in 2005. what is most striking is first. but has not prevented the implementation of special programs. During its first year. largely in response to the directives of the European Union in 2000 (Council Directive 2003a. Although the "race-relations" approach to integration has been far more characteristic of the British approach. chaps.

developed through a policy consensus between the two major political parties (Katznelson 1973: 125-126).and a struggle to manage integration in a more explicit way. Although flexible policies have been developed locally. The Sarkozy law of 2003 (Sarkozy was then minister of the interior) requires demonstration of knowledge of rights and duties of French citizens. and by providing an administrative agency as an advocate/enforcer for that policy. v^rith sanctions for violation. a requirement that was strengthened in the legislation passed in 2007. mainly through administrative actions. and has been developed as a result of challenges to that order. By focusing on access racism (discrimination in housing and employment). the French Civil Code (Articles 21-24) has stipulated that no one can be naturalized vdthout demonstrating his or her "assimilation to the French community" through knowledge of the French language. the Race Relations Act of 1965 provided an institutional base for integration that was agreed to by both major political parties. The new law required a contract for family unification. The second characteristic of French policy on integration has been a more intensive effort to require through state policy what had previously been assumed would emerge from residence and education. It has been a policy bom of a quest for public order. periodic laws that deal with integration have tended to reaffirm the principles of the Repubhcan model. and those applying were required to take two-month courses that constituted "an evaluation of language ability and the values of the Repubhc" in their home countries (Schain 2008: 57). Since 1945. MANAGING DIFFERENCE: BRITAIN The French political philosophy on integration can be compared with a difFerent kind of British multicultural approach to integration. This policy consensus was partly based on a race-relations approach to immigrant integration that was seen as sharply different from the French approach. The third characteristic of French integration policy is that it is constrained by the development of European integration (see below). The extension 210 social research . from the urban riots that have punctuated French urban life to the challenges posed by young girls wearing hijabs.

noted in 1966: "I do not think that we need in this country a melting pot. . By 1968. Thus. the difference was incorporated into the formal policy framework that was developed to manage and incorporate them. However. very quickly evolved into a broader understanding of multiculturalism. and multiculturalism (Hansen 2000: 28. as opposed to those from Canada. the race relations approach to integration had begun to take on a life of its own. This way of looking at non-European immigrant populations was similar to the way that immigrant populations were viewed in France. disconnected from considerations of immigration control (Bleich 2003: 84-85). and New Zealand) in political debates about "coloured" immigration from the 1950s on. 6). Roy Jenkins. Australia. Jenkins' perspective was reinforced by a series of reports on education. in Britain. not as a fiattening process of assimilation but as equal opportunity. race. beginning with the Swann Report in 1985. I define integration therefore. . The articulation of a positive approach toward multiculturalism. accompanied by cultural diversity. in an atmosphere of mutual tolerance" (Benton 1985: 71). . The concept of "race" in Britain was applied to virtually all "New Commonwealth" immigrants (primarily those from Pakistan and India. as an approach to ease integration with an active antidiscrimination policy. which secured a bipartisan approach to immigration. home secretary at the time. The Swann Report (Education for All) strongly advocated a multicultural education Managing Difference 211 . although it began with race relations. which was also firmly grounded in the legal system. By the 1980s. in Britain it was increasingly understood as an important dimension of such participation (Weil and Crowly 1994: 118). While in France. acceptance of this kind of pluralism (often called "insertion") was seen as a temporary substitute for full participation in society. the British approach to integration evolved out of a poUtical compromise on immigration legislation. chap.of this legislation in 1968 and 1976 then provided substantial depth to this approach. the education system had become an important proactive support for multiculturalism.

or ethnicity for staff/pupils.2001). regardless of institution. (Swann 1985) Perhaps most important was the 1997 report by the Commission on the Future of Multi-Ethnic Britain. The British riots have had many of the same characteristics of their French counterparts. By 1964. age-range. however. Similar to the French initial integration efforts. as Tariq Madood has observed. which reaffirmed the United Kingdom as a "community of communities. cited 212 social research . but the riots in Nottingham and Notting Hill in London in 1958 are generally cited as the first serious outbreaks. the British approach was rooted in a need to maintain public order (Hansard 711: 927. The most important difference has been the political consequences of the riots in each case. recognized integration as a two-way process of dual responsibility (Modood 2006: 2). location. Multiculturalism and Urban Order With roughly the same rhythm as in France.system for all schools. the 1958 events—still seen in terms of race relations—were understood as a problem to be dealt with through a new approach to integration that would focus on antidiscrimination (Bleich 2003: 45). and prevent a British Little Rock (Miles 1984: 262). The first post-World War II civil unrest in Britain was in 1948-1949 in Liverpool. riots have erupted in major British cities with high concentrations of immigrant populations (for example. and then Birmingham. Deptford. The reaction of French authorities to the first urban riots in Lyons in 1981 was to frame the problem in terms of social control and education. These conclusions have been reaffirmed by numerous reports since then. The British reaction to the riots in 1958 was to frame the problem in terms of race relations." The net effect was what one author has called "a conceptual shift" (Brighton 2007: 5) that disassociated integration from immigration—the management of arrivals—and. except that they have been more violent in terms of personal injury to residents and the police. the solution for which was to limit immigration. 1981. The report made a Unk between education and multiculturalism by noting that racism had an effect on the educational experiences of black children in the United Kingdom.1991-2.

as in many countries. linked the summer riots to highly segregated communities. Thus. Nevertheless. By 2001. the civics and language tests are meant to create a meaningful gateway for integration. there is growing pressure in Britain to assert the limits of multiculturalism and support a stronger sense of collective identity. together with certification in the English language. the kind that has never existed before in Britain. which reassociated immigration with integration by arguing that immigration should be contingent on increased civic integration and "shared values" (Joppke 2004: 253). government reports indicate the beginning of a reassertion of policies of civic integration into a society based on shared values. the attacks in London in 2005 accelerated a process that had begun four years before. in the aftermath of urban riots in the summer and the attacks in the United States in September. This was followed by a Home Office report in 2002. Although the actual policy requirements in place by 2007 were not as coercive as those in France (or the Netherlands. The Cantle Report (Cantle 2001). including France. Together with new citizenship ceremonies that include a pledge of allegiance. but the report's conclusions centered on the need to redress this situation through a "greater sense of citizenship. Managing Difference 213 .by Bleich 2003: 45). 2005. and was strengthened even after three additional rounds of serious riots between 1981 and 2001. and engagement with. the principal national institutions' (Brighton 2006:10). which was being drafted at the time of the attacks in the United States.) they were moving in the same direction (Brighton 2006)." the identification of "common elements of nationhood. The most important symbolic change in this direction has been the initiation of a citizenship test and a citizenship ceremony under legislation passed in 2002. as well as the attacks on the London underground in July 2005." and the need for the "non-white community" to use the English language and 'develop a greater acceptance of. Beginning on November 1. all applicants for naturalization were required to pass a "Life in the UK" examination. Safe Haven: Integration with Diversity in Modem Britain. Secure Borders. this approach endured. Indeed.

In addition. we should not lose track of the differences of the policy emphasis and content. MANAGING DIFFERENCE: THE UNITED STATES The multicultural ideal of the United States as a "nation of nations" is a recent phenomenon. compared with the French control over educational content through the ministry of education. compared with the new French requirements for naturalization and family unification." and that they could be expelled if they did not (Williamson 2006). The British debate about the new national curriculum is relatively mild. The government is also pursuing cooperation at the European Union level that began with the French initiative at the meeting of interior ministers (G6) in March 2006. while the British have become increasingly concerned with questions of civic integration. governments devoted greater attention to what has often been phrased as a "hearts and minds" approach to Muslim communities—that is. These outreach efforts have been far more extensive than similar programs in France. (then) Home Secretary Charles Clarke noted that he supported a more muscular integration contract that would ensure that "new immigrants live up to the values of our society. but not the content of the policy itself. we should be clear that convergence indicates a direction in the policy process. the French state has become a far more important actor in the integration process through direct intervention. Compared to Britain. although it does appear to be devoting more resources to civic integration. by government attempts to enlist Muslim individuals and community organizations in their efforts to enhance security. Thus the French have begun to focus on issues of discrimination. dating more or less from the period around the Second World War. however.^ At that time. In focusing on the convergence of policy concerns. The British citizenship examination is also mild. After 2005. During most of the nineteenth century there 214 soclai research .The Public Philosophy The British government has not reversed course on multiculturalism.

1. 1. Although this ideal lacked some of the institutional support of the French Jacobin model (in particular a national system of education). 3-5). In the literature on the development of American identity there is considerable discussion about the difference between the "new race" idea—that Americans were/are an amalgam of European cultures. Higham 1963: 234). Native Americans. chap. The most important impact of the "new" immigration of the early twentieth century was the ñrst government attempt to link naturalization policy with ideas about what it meant to be an American—the first "Americanization" programs (Higham 1963: 140-142). The ideal gained increased institutional support at the local level. and that Asians. the literature on the ideal of immigrant integration during the nineteenth century in the United States—whatever the contradictions in reality—seemed destined to play a role in America not unlike that of the French Republican model." Basically. and supported English as a common language. that other European cultures (Catholic and German in particular) were far less welcome as part of the melting pot. It supported intermarriage and the hegemony of English cultural and political values together viâth English as a common language. easy melting of many peoples into one. the Americans sought to brake the incoming current or to inhibit its political power. Managing Difference 215 . Assimilation would flow from the operation of social institutions. what John Higham has called "a confldent faith in the natural. Indeed. otherwise they trusted in the ordinary processes of a free society" (Lowi 1969. even if ethnicity did in fact form a basis for initial settlements and poUtical organization for collective advancement (Fuchs 1990. this reflected a more widespread attitude about the nature of American homogeneity and the basis of American citizenship that endured until the last decade of the nineteenth century.seemed to be a sense among social and political leaders of something increasingly "American. chaps. chap. vdth the whole being distinctive and different from the parts—and the "modified Englishman" idea: that Anglo-Saxon culture has dominated the American ideal. it did provide an Anglo-Saxon ideal. as education spread after the Civil War. When fearful of disruptive influences. Bridges 1984.

Americanization programs were cut back due to the pressures of economic contraction. Nevertheless. but the ideals and values remained dominant until after the Second World War. Efforts to harmonize these efforts were coordinated by the Committee for Immigrants in America. a private group sponsored by wealthy progressive donors. the unique goal of which was to publicize the need for immigrant Americanization through education. The committee finally gained the support of the Bureau of Education in Washington. within which was established the Division of Immigrant Education. there was a vñdespread assumption among public and private leaders on every level that there was a pervasive cultural homogeneity in the United States. six states in which large numbers of immigrants were concentrated organized commissions and programs that combined investigations into the living conditions of immigrant populations with civic education programs. there is little doubt that at least until the First World War.and Blacks were excluded from the pot entirely (King 2000: 14-19). and that "interchangeability and assimilability were deemed necessary conditions for citizenship" (BCing 2000:18). but numerous states continued what had become a crusade by passing coercive legislation that ranged from requiring that English be the sole language of instruction in all public and private primary schools in 15 states. to requiring that non-English-speaking aliens attend English classes in two states. and by the recognition of the legitimacy of a multiethnic America that was portrayed by government propaganda during the Second World War. to more draconian measures that were eventually declared unconstitutional (Higham 1963:260). By 19211922. by the emergence of what Martin Kilson has called "Black neoethnicity" in the midst of 216 social research . Multiculturalism and Urban Order The movement toward multiculturalism was given impetus by a process that began with ethnic organization between the First and Second World Wars. It was substantially reinforced. Federal support for the Americanization effort began to ebb after 1920. On the eve of the First World War.

" represented an attempt to deal vdth a racial crisis.the civil rights struggle the 1960s (Kilson 1975). part V). One indication of the change came in the legislation passed in 1972.^ Institutions that were set in place to deal vwth race problems in the United States had a direct impact on the approach that the government took in shaping immigrant integration. and signed into law by President Richard Nixon.'^ began to emerge at the same time that intermarriage among the children and grandchildren of European immigrants was sharply on the rise. The role of the federal government in shaping a multicultural approach to immigration can be understood on several levels. a Nation of Immigrants. when the House and Senate Managing Difference 217 . the change in public philosophy was related to urban and racial tensions. 266-276. not immigration or assertions of multiculturalism. For Glazer. and when important indicators of ethnic "memberships" were on the decline (organizational membership and language ability above all). Fuchs 1990. Indeed. the ideal of neoethnicity. The Immigration Act of 1990 included a program of "diversity visas" that would eventually provide for the admission. it had far more to do v^dth urban unrest and the civil rights movement than with immigration. Black Americans became the "storm troopers" in the battles about multiculturahsm (Glazer 1997: 94). In this sense. As in Britain and France. and history curricula were altered to include African Americans. of 55. Nathan Glazer has argued that Black neoethnicity was a direct result of the failure of the integration efforts of the early 1960s. At the most basic level. Native Americans. but had unanticipated responses. Congress voted $15 million to fund an ethnic heritage program. Government programs in the 1960s that were said to create minorities "by ascribing to them certain characteristics that served to justify their assignment to particular societal roles. Indeed. as well as a variety of ethnic groups (King 2000: 32. immigration law now favors and promotes diversity.000 immigrants from "underrepresented" countries chosen by lottery. What began as an effort to relieve the backlog of applications from Ireland ended as a mechanism for increasing the diversity of the population of the United States. on an annual basis.

These rules not only included immigrant groups in their mission. but also provided the basis for proactive action by the EEOC that promoted the employment rights of diverse groups. and for job creation" (Tichenor 2002: 274). and local levels has both permitted and encouraged multiculturalism in the United States. American political leaders were seeking to promote what European leaders either feared or sought to carefully manage: cultural diversity. The absence of state sponsorship in the United States does not mean that religious organizations are not accorded a privileged status. Under specific conditions. the Voting Rights Act of 1965 has been applied to immigrants in ways that promote diversity. Under rules developed by the Equal Employment Opportunity Commission (EEOC) in 1965. A second key federal program that has shaped the national approach to multiculturalism is the antidiscrimination effort initiated by the Civil Rights Act of 1964. Since 1975. it is driven by institutionalized interest group activity. Even as an afterthought. the approach to religious diversity at the national.conferees emerged with a final agreement on the 1990 legislation. In the same way. however. policy was initially formed in the context of a need to promote and maintain public order Increasingly. including immigrants (Blumrosen and Blumrosen: 4). but about their sex and ethnicity as well.^ Finally. In each of these areas. Various forms of recognition are also implied when local governments recognize religious holidays as a reason for school absence and suspension of restrictions for parking cars. they called their compromise agreement a victory for cultural diversity. employers were required to file annual reports not only about the race of their employees. state. "for family unity. the Voting Rights Act has required ballots and other election assistance in languages other than Enghsh in jurisdictions where at least 5 percent of voting-age citizens are not proficient in English and literacy rates are below the national average. they are granted a special tax status that permits exemption from both national and local taxes. Well organized ethnic interest groups have protected and expanded entry require- 218 social research .

One important change is that Muslim organiza- Managing Difference 219 . The flrst is that most Arabs in the United States are not Muslim (25 to 30 percent are estimated to be Muslim). the Muslim-immigrant community in the United States is very small. Thus.ments that favor their constituencies (Fuchs 1990. and has not been implicated in patterns of urban unrest. Finally. dietary restrictions. chaps. Although officially there are no public funds for the construction of mosques available under the American version of separation of church and state. has not posed the same challenge to integration policy in the United States that it has in Europe for three speciflc reasons. and Catholics before them. 13. as well as for the construction of schools. Islam. In a way that followed similar arrangements for Jews after the Second World War. have eased the way for Muslims through established institutional arrangements and legal precedents. the precedents of Jews. business groups have been consistently active in ensuring access for Mexican and Latin American workers for agribusiness. and holidays (the lead having been taken by African American adherents) beginning in the 1970s (Zolberg 2004:17. Cornehus 2004:1). Nevertheless. the pattern of integration of Islam in the United States provides an interesting case study. Andreas 2000. however. In addition. and at least a third of American Muslims are African American and not immigrants at all (Project MAPS 2004:47-48). This relatively easy relationship declined after 2001. 18). and therefore does not have much influence on thinking about immigration policy. as Zolberg has noted. Therefore. schools and workplaces recognized Muslim dress codes. following the pattern established for Catholics and Jews. 51). but the process has remained the same. illegal border crossing at the Mexican border and the enforcement of controls can be seen in terms of cycles of enforcement that reflect the influence of employer interests (Schain 2008: 219-220. in general there were no problems using funds ñ:om foreign sources for their construction. The second reason is that the Muslim immigrant community in the United States is predominantly middle class.

have a durable permissivefi-amework. 4 and 324-331). in the United States there has been little attempt to reinforce or reinvent policies of civic integration. Unlike what has occurred in Europe. CONVERGENCE AND THE EUROPEAN UNION Christian Joppke has made a persuasive argument that—in part as a reaction to perceived failure— there has been a convergence of integration policy in Europe around civic integration and antidiscrimination 220 sociai research . much as Catholics and Jews had done in earlier periods (Hagopian 2004: 9-71. activists in these communities are looking at the experience of other immigrant groups as a model of how to understand their own position in American society (Nagel and Staeheh 2005). born of public policy strategies to deal with urban unrest and racism. in different ways. The United States does not have an explicit integration policy. It does. rather than immigrant immigration.based in constitutional law (dealing mostly with questions of discrimination and the establishment and expression of religion). and on legislation. and the United States have moved toward different kinds of multiculturahsm. Perhaps more important. the questioning of the American multicultural model was far more intense during the years before the crisis of Islamic extremism than during the years since (Schuck 2003. have been important in shaping integration of immigrant communities since the 1960s by providing a strong. What appears to be a laissez-faire policy on integration is nevertheless shaped in a variety of ways by the states and by the federal authorities. has endured challenges and debates during the past 30 years. Thus. at least at the national level. In fact. Relevance of the Public Philosophy The public philosophy of multiculturalism in the United States. the integration processes in France. Pohcies originally developed to deal with race relations.tions have now increased their role in defending civil rights. chap. proactive national antidiscrimination structure that served as a model for the British eftbrt after 1965. however. MacFarquhar 2006). Britain.

Indeed. brought questions of immigration. First initiated in Britain in 1965. The initial step was to create a committee of experts to investigate the procedures used in all member states. when he was the French minister of the interior. The compulsory aspect was finally dropped in June. the interior ministers of the six largest European Union countries (the G6) agreed to pursue the idea of an "integration contract. knowledge and commitment to the values of the receiving country. religion or belief. Policy would be harmonized on the basis of proposals made by the commission. age. the antidiscrimination approach was given a major push by the Treaty of Amsterdam in 1997 and two directives of the European Council in 2000 (Council Directive 2003a. The treaty.^ At the same time. The directives obligated all EU countries to constitute commissions that would both monitor and act against patterns of racial discrimination. one of the first initiatives of the French presidency in 2008 was to propose a comprehensive. antidiscrimination programs in all European countries have grov«i in importance. Since then Managing Difference 221 . In March 2006. and actions of the Council of Ministers. The development of a policy of civic integration was moved to the European Union level at the initiative of Nicolas Sarkozy. and have increasingly benefited those immigrants who have made it past the door. They then planned to propose such a policy to the other 19 countries of the EU. compulsory EU integration program. or sexual orientation) into the EU structure. racial. The new trend tends to emphasize civic integration policies that create an obligation for immigrants who wish to attain the rights of citizens to individually demonstrate that they have earned those rights.policy (Joppke 2007: 243). 2003b). disability. and to some extent integration (particularly the revised Article 6a on how to combat discrimination based on sex. Three criteria were accepted for acceptance and integration in Europe (according to the French government): language mastery of the receiving country. which came into effect in 1999. but a "European pact on Immigration and Asylum" was passed by the European Council in October 2008. or ethnic origin." using the French model as a starting point. and access to employment.

this issue has not been nearly as important for the Americans. FAILURE AND SUCCESS The French. For the British. in particular the acceptance of a common public space that is separate from religious faith and expression. but implies a civic commitment to political-culture values.the emerging institutions have begun to offer immigrant communities a measure of recognition and protection. and American models imply criteria of success and failure based on their objectives. the second has given new support and legitimacy to racial and ethnic diversity. The American multicultural model implies a similar commitment to what Lawrence Fuchs has called a permissive civic culture that protects diversity (Fuchs 1990: xv). and U. The British model accepts cultural and racial and religious diversity as a necessary dimension of participation in society. The United States has long required some aspects of civic integration now being promulgated in Europe. vdth the beginning of cycles of urban violence that culminated with nationwide riots in November 2005. Thus. and has grown vdth intensity after the attacks in July 222 social research . as well as conformity with French cultural and legal norms. the acceptance of common cultural and historical references is important. antidiscrimination policy was a model for the British program. For the French. the perception of failure began in the early 1980s. In the French Republican model. rather than simply a way station to a deeper nationhood. The policy debate has tended to focus on the failure of the school system to effectively integrate new waves of immigrants as effectively as it had previous waves. which is now—in turn—a model for other European countries. If the first has constrained policies of multiculturalism. both of these evolutions in policy have created overlapping similarities in the approach of all European countries to questions of immigrant integration. the perception of failure began in 2001. Although perceptions of policy failure of integration have been widespread and politically salient for the French and the British. British. on spatial concentrations of immigrants. and on urban unrest.S.

In the American case. one set of standards that we can use to evaluate relative success and failure has been formalized in a list of "Common Basic Principles for Immigrant Integration Policy in the European Union. the reference to national models has sometimes blinded the government to its success.2005. goods. If we look at two dimensions of integration. but has faded since (Sahns 1997. the perception of failure was widespread among intellectuals during the decade of the 1990s." agreed to in the Hague Program in 2004 as part of a common program for integration. and has made it more difficult to deal with its failure. it is evident that success in one does not necessarily predict success in the other. In each case. the most important are employment as a key part of the integration process. The problem is that in each case. and services. Peter Hall has argued that policy failure and attempts at adjustment may very well lead to further failures (Hall 1993: 79).^ From these principles. Jr 1991). Not surprisingly. unemployment rates among immigrant populations have been generally higher than those of the native population. these principles generally refiect criteria that are also used by specialists to measure degrees of integration in the United States. As a result of the Amsterdam Treaty. relative success in education and employment may correspond with evident failure in the convergence of value acceptance (see fig. socioeconomic and cultural. the policy focus implied by the national model has been successful in achieving critical objectives. Huntington 2005. with the exception of the United States. education as critical to preparing immigrants to be more successfiil and more active participants in society. and in important cases. part III. and participation of immigrants in the democratic process and in the formulation of integration pohcies and measures (Council of the European Union 2004: 19-24). Schessinger. where relatively high unemployment rates among Hispanics offsets higher employment among Managing Difference 223 . Among the 11 agreedupon principles. At their core. while what has not been emphasized has resulted in failure. access for immigrants to institutions. 1). we can derive several measures of integration that can give us some indication of relative success and failure.

the proportion of immigrants who drop out. Moreover. Compared to the United States and Britain. youth unemployment is also highest among the French. Yet. unemployment is higher by far among French immigrants. almost three times the level of immigrant youth unemployment in the United States (see table 1)! Educational attainment is more complicated. however. Educational attainment among immigrant populations at the university level is as great as or greater than that of the native population in all three countries.other immigrant groups. or who never get to SUCCESS IN CULTURAL/VALUE INTEGRATION + SUCCESS IN SOCIO-ECONOMIC INTEGRATION — US UK + FR NL Figure 1: Two Dimensions of Integration Success/Failure 224 social research .

Managing Difference 225 . November. 2005: 65. 2004 Less Tinan Upper-Secondary Education Native-born France Britain US University Degree or Greater Native-born 13% 20 27 Foreign-born 56% 45** 32. 2004.5 •UK = no qualification -"O" level. Some of this difference can be accounted for by differences in socioeconomic status.Table 1: Unemployment Rates for Immigrants and Natives in 2 0 0 4 Immigrants France Britain Netherlands US 13. including France and Britain. if we control for socioeconomic status. 23. while in Britain. European Community Labour Force Survey. This is important because educational attainment has Table 2: Educational Attainment of Immigrant Populations.7 3. very high in the United States. Enquête emploi de 2005. France = 50% Sources. US.8% 7.8 Foreign-born 12% 28 27 35% 49 12. lack of achievement at the lower levels continues to be significant. US Bureau of the Census. INSEE. and science among immigrant children in 10 countries.9 Sources: Data from OECD 2006: 73. 33-36. is disastrously high in France. Dustmann and Theordoropoulos (2006): 20. Low achievement scores were almost 40 percent higher in France. compared with Britain. upper secondary education. US Congress (2004). but comparatively low in Britain (see table 2).0% 4.8 Nonimmigrants 8.3 5. compared with native children of the same age. These differences are confirmed by an analysis of achievement scores in reading.6 6. first-generation immigrant children do as well (or as poorly) as others of the same age (Schnepf 2004: 12. European Community Labour Force Survey.3 10.40). math. (France and Britain): OECD in Figures. A Description of the Immigrant Population.. France = BEPC (first-cycle high school) "no qualification: UK = 10%. In France. CBO.

1 Medium Education 14.5 9.Table 3: Unemployment Rates of Foreign-born Populations by Level of Education Attainment.7% 6. 2004 % Population France Britain US 5% 7.8 4. France has been at least as accepting of immigrant populations as Britain. 226 social research . the idea that "immigration is having a good influence" is (perhaps surprisingly) accepted in Europe.6 3. Nevertheless.0S Source: Alba and Foner (2009).3% 2. Low/ High -36% -66% -49% -53% Source: Data from OECD (2006: 53).9 12. 2003-2004 Low Education France Britain Netherlands US 18.4 % State/ Local Reps 3. but sharply different at the national level. election of immigrant candidates to political ofñce is a measure of their integration "in the same sense that entry by minority individuals into high-status occupations is (Alba and Foner 2009).6 7.2 (state) % National Representation 0% NA 2. even more accepting.3 HR/3. attitudinal surveys indicate that by several measures. As Richard Alba and Nancy Foner have noted.3 5. and by others. France has consistently had the worst record by far in this area (Anwar 2001). Indeed.4 7.9 7.7 High Education 11.2 3.3 Diff. Political representation can be understood as integration through politics.5 % Electorate 2. and the confidence that Muslim immigrants Table 4: Political Integration of immigrant Populations. where the more porous American system has generally succeeded in providing better access than either Britain or France.3 4.2 6. a Strong impact on unemployment rates for immigrants (for natives as well) (see table 3).3 5.4 12. Table 4 indicates that immigrant representation is roughly similar for all three countries at the local/ state levels.

programs to keep immigrant children in school may be more important that high-profile programs to place them in elite universities. French people who identify as Muslim appear to be the most "European. The French record of placement of immigrants in the university system is better than is often assumed. however. where almost two-thirds of immigrants did not attain the level of upper secondary school. and compared vdth other countries (Britain and the United States. Muslim immigrants in France of Islamic origin. is the worst of the three. they have the most positive views of their compatriots who are Christian (and Jevdsh). French Muslims are the most integrative in their orientation and the least confiicted between their Muslim and national identities (see table 6). Thus. Nevertheless. by far the largest Muslim community in Europe. and 50 percent simply dropped out without any degree (INSEE 2005: 5). Therefore. have the strongest national identity and are the most inclined toward integration. The British record of educational integration appears to have been remarkably successful (even if we control for SES). These figures. combined with periodic urban violence.seek to adapt to customs in their country. the British and American records of economic integration of immigrant populations are far better than that of France. In addition. for example). the French record. Within Europe. a recent study of Muslim elites in Europe indicates a similar pattern. among immigrant groups in Europe. Managing Difference 227 . These societal attitudes are refiected in attitudinal patterns among the immigrant population who identify as Muslim." As a minority community. No doubt the poor French economic performance is linked to the failures of the educational system. and that there is no confiict between devout Muslim practice and living in modern society. but school retention is far worse than is often stated. and the record of the United States somewhat less so. and are among the least sympathetic to radical Islam. is far more strongly held in France than in other countries (see table 5).^ They are the most supportive of ideas that are consistent with the French Republican model. in comparison with policy in the past. have left the impression that French immigration policy has failed.

management of the old differences— generally reflected in national models—generated dynamics that still play an important part in the political life of their societies.10. it is useful to look at three dynamics: direction. France has moved toward more robust antidiscrimination policy. In analyzing policy convergence. In this process. are relatively weak. perceived failures in the management of new differences. On the other hand. however. content. the management of difference plays an important role. and has developed policies that tend to favor some "positive discrimination" in education. have resulted in what is often termed a process of convergence. Both sets of policies. combined with pressures generated by European Union. They are severely limited by the assumptions 228 social research .Table 5: Attitudes Toward Immigrants and Muslims A good thing people from ME and N Afr coming to your country French Response British Response Spanish Response German Response US 58 Immigration having good influence on your country Muslims in your country mostly want to adapt to national customs No conflict between being a devout Muslim and living in modern society 74 Growing Islamic ID good 46 45 11 57 43 22 35 27 62 34 45 47 52 21 36 13 11 37 17 33 26 42 Source: Pew Research Center (2006a: 3. 8. and intensity. IPSOS (2006). 2006b). 6. Although there has been a movement toward conversion of integration policy in France and Britain. compared with the British efforts. this movement has come from very different directions. CONCLUSION In the politics of integration.

important with tlon: % Yes Men/women part of your life % No Difference "Muslims in ID with in your country want to adopt national customs different "country" religious and practice a "religion": threat to our way of life Paris Muslims London Muslims 9% 5% 20% 7% 23% 9% 6% 22% +1 -12% 78% 41 Source. of the French model.Table 6: Muslims in Europe: Attitudes Toward Identity. more in Britain and France than in the United States. education policies seem to have worked relatively well. In each case. however. Fellow Citizens. Nyiri (2007). In all three countries. and the civic integration effort has resulted in considerable confusion about "the common elements of nationhood. Nevertheless. often in contradictory ways. there has been a movement toward more intensive policies. more recent efforts to provide muscle to civic integration policies are well within the French tradition. while antidiscrimination policy has been strengthened in favor of positive support for multiculturalism. On the other hand. Indeed. the timid policy movements have been shaped and limited by the dominant policy paradigm based on national tradition and national struggles to integrate new immigrant populations. the clear failures Managing Difference 229 .11-12. 2006b). Convergence in Britain has taken the form of a movement toward policies of civic integration. that paradigm has been stretched and modified. and reconsideration (at least at the margins) of the multicultural national curriculum. policies of civic integration have been weakened over time. in France and Britain. convergence has come from a very different direction. and Modernity Removing headscarf Religion People necessary for ntegra." In the case of the United States. In each case. and are hobbled by limits on gathering and using data on discrimination. based on a perceived but different sense of policy failure. However. "Source: Pew Research Center (2006a: 3.

^" In many ways integration policy on both sides of the Atlantic is converging—both in terms of expectations and in terms of permissive and proactive state action. 78-17 du 6 Janvier 1978 relative à l'informatique." The decision of the Constitutional Council was elaborated in Le Monde (November 25. Kennedy's remarks echoed the main 230 social research . Kennedy in 1957 and published by the Anti-Defamation League in 1958. The phrase is a title of an essay written by John F.do not seem to have undermined the authority of the existing policy paradigm. France has accepted multiculturalism as a condition of social order. multicultural policies have been shaped by immigration law and antidiscrimination instruments that emerged from the civil rights movement. 2. auxfichierset aux libertés. NOTES 1. It was pubhshed commercially 1964. While the European Union (EU) 15 have an index of 60 (out of a possible 100). and in the United States. This was one of a continuing series of meetings of the six interior ministers of the largest countries in Europe that have taken place outside of the formal EU context since 2003. The legislation that authorizes the prohibition against the collection of ethnic data is Loi no. 2007). and its advocates have retained both their passion and their legitimacy. if not in principle. the British 63. In practice. Many of these differences are reflected in the annual report (since 2005) of the Migration Integration Policy Index. This helps to explain why—at least until novi'—important national differences remain. it varies between a low of 39 for Austria to a high of 88 for Sweden. The National Commission on Computers and Liberty lists seven criteria that could be used to measure "diversity. While French practice has been more multiculturalist than is generally acknowledged. Britain has promoted multiculturalism through a broad spectrum of public policy since 1965. modifled in 2004. 3. the American instruments that have supported multicultural policy have also been stronger than is generally understood. 4. The French index is 55.

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