Building on and generalizing from his monograph on aliens, naturalization, and the law in the U.K. and the German states during the nineteenth century, Andreas Fahrmeier has written a broader history of the concept and practice of citizenship in Great Britain, France, Germany, and the U.S. between the French Revolution and the present. Done in a prose style that is more functional than ornamental, the book offers a plethora of information, drawn from wide reading in the secondary literature and occasional forays into the British archives. Fahrmeier's conceptual organization of this material brings out both the broader trends among the four countries he studies as well as nationally specific developments.

Central to the author's approach is the idea, loosely drawn from the British philosopher T. H. Marshall, of decomposing citizenship into four separate components. One is formal citizenship, membership in a polity. A second is political citizenship, a voice in a polity's decision-making, which Fahrmeier operationalizes in terms of the franchise. Then, there is economic citizenship, the right to participate in the labor market, and social citizenship, claims on benefits from state social policies.

Fahrmeier's historical analysis is divided into six separate eras. The age of the French Revolution marked the invention of citizenship, replacing old regime conceptions of political belonging based on the categories of the society of orders, in which distinctions between indigenous inhabitants and foreigners were vague at best. Following the revolutionary period was a liberal era, 1815–1870, in which monarchical and republican states developed variations on the initial revolutionary ideas, but formal legal criteria remained flexible in practice. Fahrmeier argues that the years between 1870 and 1918 saw an increasing “ethnicization” of citizenship, when rights and obligations connected to membership in a polity were reformulated in terms of common descent. The 1919–1945 period was one in which previously existing ethnicization was raised to a new and ominous level, a period of increasing racial engineering. In the postwar era, 1945–1970, Fahrmeier argues that previous ethnic connotations of citizenship were gradually dissolved. Most recently, he concludes, the creation of the European Union and the population and economic flows of globalization are beginning to make the entire legal construction of citizenship obsolete.

All sorts of questions can be raised about Fahrmeier's conceptual approach, his periodization, or his placing of specific national examples within his broader categories. To take just one example, in Great Britain, the post-1945 era saw the reinforcement of the ethnic character of citizenship rather than its decline, as previous understandings of being subjects of a worldwide British Empire gave way to strict limitations on the ability of non-white subjects or former subjects of that empire to enter the British Isles. For the purposes of this review, I will confine myself to three broader observations: 1) the disjunction between formal-legal regulations and actual practice, 2) the importance of the age of total war for the development of the practice of citizenship, and 3) the place of the German state(s) in the broader picture the author offers.

One of the strong points of the book is that Fahrmeier does not confine himself to explicating the legal regulations concerning different aspects of citizenship, but investigates their actual implementation, frequently finding discrepancies between the two. For much of the nineteenth century, Great Britain had very strict rules about naturalization and its consequences—naturalized citizens could not be government employees, for instance—but in practice made the least difficulties for foreigners in settling or working in the country. Fahrmeier argues, and I would agree with him, that in Great Britain and the U.S., countries with pronounced laissez-faire traditions and policy preferences, restrictive regulations were and are most likely to be overlooked in practice.

After reading Fahrmeier's account, it is difficult to avoid the impression that the age of total war marked a decisive break with the past in regard to citizenship. It was only after 1914 that passports came into common use, that governments began to control their borders in rigid fashion, and that statelessness or refugee status became mass phenomena. The very ideas of social and economic citizenship, basically unknown in the nineteenth century—Fahrmeier shows, for instance, that pre-1914 social insurance systems paid no attention to citizenship—only developed in this period. To be sure, there were earlier foreshadowings of the situation after the Great War—the exclusion of Chinese and Japanese immigrants from the United States, for instance, or the 1913 Reich citizenship law—but these and other restrictions on the free flow of individuals across state borders, and even the stricter ones discussed or proposed before 1914, rather pale when compared with the restrictions, demands for documentation, and intrusive state surveillance of the post-1918 era.

Fahrmeier, as might be expected from his previous writing, rejects the idea of a German citizenship Sonderweg, characterized by a long-term emphasis on descent and ties of blood, legally expressed as an ius sanguinus against more flexible concepts of citizenship based on political allegiance, finding legal expression in an ius soli. His arguments on this point are generally convincing, but it is hard to avoid the impression that over a longer period of time, and certainly in the post-1945 decades, both formal legal regulations and the actual practice of extending citizenship rights to immigrants have been more restrictive in Germany than in the other countries Fahrmeier discusses. This is perhaps a reflection of the many nineteenth-century decades in which Germany was an overpopulated country, where emigration far outweighed immigration, and the domestic labor market was tightly controlled. Fahrmeier's pre-1914 examples of economic citizenship refer primarily to central Europe and to the persistence of old regime style, guild-based restrictions on settlement and employment. These were concepts basically unknown in the other countries in his study, although, of course, found in Austria and Switzerland. It is, perhaps, the combination of this tradition and the mental habits it has inspired, with a skepticism about the beneficial effects of laissez-faire, and the existence of an effective state bureaucracy and legal system, that has led to a more restrictive understanding and practice of citizenship rights in Germany than in many other economically advanced countries.