Introduction
Since the 1980s, the question of citizenship has taken root as a major
theme in the social sciences and as the focus of juridical, political,
social, and cultural debates in all democratic societies. In Europe,
citizenship has taken different shapes and definitions in its rhetoric,
ideology, and practice with regard to immigrants; incorporation into
nation-states and their expansion of political participation beyond
boundaries relating to home and host country to include a broad European
space. Citizenship is also an issue for European construction itself.
Within nation-states citizenship has been expressed in different domains
extending from the national community to the civil society, even though
only “legal” citizenship allows the full participation of individuals
and groups in the political community. At the European level, despite
the transnational participation of immigrants encouraged by the very
nature of the European Union and its supranational institutions and
de facto expansion of dual citizenship, the claim for equal
recognition as citizens that underlies the political strategies of
immigrants remains within the framework of the legitimacy of the state
of residence and citizenship.
The question of citizenship therefore opens the way to negotiations of
identities between states and immigrants (Kastoryano
2002). Within nation-states the struggle for equality that
citizenship entails is extended to different domains, often turning
negotiations of interest into negotiations of identity. For states, it
is a question of negotiating the means of inclusion of immigrants into
the political community on the basis of a new equilibrium between
community structures and national institutions. For individuals,
citizenship becomes a principle of equality and a way to struggle
against political, social, and cultural “exclusion.” It becomes a way to
claim recognition as a “citizen,” through which the attachment and
loyalty to both a national and an ethnic community are expressed,
thereby combining a liberal and republican participation (Dagger 1997). Such an understanding of
citizenship raises the question of the relevance of the triple link
between citizenship, nationality, and identity, hence the link between
political community and cultural community, the former as a source of
rights and legitimacy, and the latter as a source of identity. At the
European level, the construction of a new political space creates an
opportunity for action beyond boundaries, leading to transnational
structures of representation and to new negotiations with states—home
and host—and introduces the question of territoriality with regard to
the practice of citizenship and its relation to nationhood.
This article explores these complex articulations of belonging and the
actions generated by the question of citizenship and analyzes the link
between cultural and political belonging, between rights and identity
and the relevance of territoriality in relation to nation and new
expressions of nationalism raised by forms of transnational
participation.
Citizenship, Nationality, and Identity
The concepts of citizenship and nationality, two interdependent and
“interchangeable” (Leca 1992) concepts within
the framework of a nation-state, are defined above all by membership in
a political community. This membership takes shape through rights and
duties that are embodied in the very concept of citizenship. Its
implementation by law implies the integration or the incorporation of
the “foreigner” into the national community with which he or she is
supposed to share the same moral and political values. Moreover, she or
he is supposed to adopt or even to “appropriate” historical references
as a proof of belonging and loyalty to the founding principles of the
nation, which according to Weber is the only community born of
modernity.
Debates on citizenship and nationhood reveal precisely such expectations,
whatever historical interpretation and juridical shape is given to
citizenship. Based on the example of France and Germany, citizenship and
nationhood have been analyzed in ideal-typical terms opposing a cultural
and ethnic understanding of the nation to a civic and political one
(Brubaker 1992; Dumont
1991). The reality, however, is more complex. Obviously such
representations of the nation have explained, and to some extent
justified, policies and laws of citizenship in democratic states. But
lately, the experience of immigration and settlement along with the
claim for recognition of cultural particularities and equal citizenship
have changed the understanding of citizenship, and carried its practice
beyond its legal definition.
A normative version of citizenship embodies values and action,
“responsibility and civic virtues” (Kymlika and
Norman 1994). Citizenship is therefore not limited to
political status and rights related to a national identity; it is also
an identity that is developed through direct or indirect participation
in the name of a shared interest for individuals and groups, immigrants
or not. It is expressed through the engagement of the individual for the
common good.1
Citizenship as a subjective
feeling of membership and citizenship as engagement. See, Leca
(1986).
Such an
engagement can take place within voluntary associations, through
community activities (local or broader cultural, ethnic, and religious
activities), in short, through an engagement toward the civil society as
well as the political community. Citizenship is interpreted, then, as a
participation in the public space, defined as a space of communication,
of shared power, as well as a space of political socialization and where
a “citizen's identity” is acquired and constitutes a political resource
for action and negotiation.
Therefore, a normative approach to citizenship extends its understanding
and its expression in social and cultural domains to include them into
the political. According to Kymlicka (2002),
the extension of citizenship to ethnic communities today is a way to
integrate these communities in a common national community, as was the
case with the reconsideration of citizenship with regard to the
participation of social class analyzed by T. H. Marshall. On the other
hand, actors devise strategies for participation according to legal
citizenship applied in nation-states. In France and Germany, for
example, immigrants develop different tools and devise different
strategies for political participation. In France, access to citizenship
is based on a relatively easy process of naturalization and the practice
of jus solis for the young generation immigrants, leading to
direct participation whereby they can act as an electoral force. In
Germany, on the other hand, until very recently restrictive citizenship
laws included the interdiction of dual citizenship for those who wished
to maintain the citizenship of their country of origin, prompting
activists to develop “compensatory” strategies.2
Though Germany has applied the principle of jus solis
for children born on German territory since 2000—if the parents
have been official residents for the last eight years—it is too
soon to predict its political impact. Likewise, even though the
process naturalization has been made easier, and the number of
naturalized foreigners increased, it is still soon to measure
their political and electorate impact.
Such strategies
entail a search for indirect participation that implies a participation
in the civil society through mobilization within voluntary associations
as a way to assert a collective presence affecting public opinion and
political decisions on their behalf. However such a “social citizenship”
that initiates the exercise of citizenship and includes foreigners in
its existing corporate structures translates into an indirect
participation with regard to purely political citizenship.
3 Habermas makes the typology between “passive
citizenship” and “active citizenship.” The former finds its
legitimacy in the development of the welfare state and does not
include participation in the political community. The latter
requires an “active citizenship,” in J. Habermas (1995).
Only legal citizenship
carries the right to equal direct participation in the political
community in the full sense of the term. It is acquired, for foreigners,
through the process of naturalization, a process that takes into
consideration the length of their stay, their contribution to the
society, and a “natural” identification with the national community.
A citizenship that expresses itself in both community and national
institutions runs against the traditional analysis of republican
citizenship that blends political involvement and national sentiment,
because citizenship is systematically attached to its structure, the
nation-state, where identity-based and political aspects are blurred.
But at the same time the empirical reality of citizenship implies a
conceptual and interpretative polyvalence. Whether citizenship is
political, judicial, social, or economic and its content identity-based,
cultural, or juridical, this combination boils down to a sense of
loyalty directed at once toward the group, the community, civil society,
and the state. It is through their interpenetration that the actors;
strategies emerge.
Thus citizenship in practice and as discourse is linked to the phenomenon
of exclusion, to ways to counter social exclusion and to foster
political inclusion. On the other hand, citizenship as civic
participation does not always theoretically preclude the expression of
collective identities. All the more so since migrants who arrived in
different European countries in the 1960s and their descendants publicly
express their attachments to the country of origin, a linguistic,
ethnic, or religious community, or a local community, as well as to a
transnational community and the European Union. Their participation
combines both the interests of an ethno-religious or cultural community
and the political community. The principle of new ethnic identifications
defined in religious or national terms from local to transnational
becomes one of the stakes of citizenship open to negotiation.
Such an evolution brings to the fore a multiplicity of allegiances that
all plural democratic societies face. These have crystallized around
debates on dual citizenship, mainly in Germany. For the group, dual
citizenship is founded on a logic that has two consequences: it
transforms nationality into an identity rooted in the country of origin
and it makes of citizenship an entitlement within the country of
residence: identity vs. rights. On such a view, citizenship becomes
simply a legal status, and nationality is merely defined along the
religious, ethnic, or cultural lines that constitute the identity of the
home country. In Germany, for example, by demanding dual citizenship,
Turks define citizenship as a judicial tool that gives them political
representation and nationality as an ethnic identity. Dual citizenship
flows therefore from a duality that appears, a priori,
contradictory but is in fact complementary: the construction of a
minority status and the creation of a citizen's identity. Both emerge
within the country of residence's institutions. How, then, can the
relationship between citizenship and nationhood be defined? A
citizenship linked to the nation of the home country thereby
de-territorialized, or a citizenship related to an ethnic community
seeking recognition not only within the national political community but
on a European and international level, therefore de-nationalized and
de-territorialized? Such a question suggests that ethnic communities
become “transnational nations” derived from the interaction between home
and host countries and with a broader space of transnational
participation.
Citizenship, Transnationalism, and Territoriality
Dual citizenship relates de facto to transnationalism. The
increasing fluidity of borders has led immigrants to develop
transnational networks linking the country of origin to the country of
residence and to participate actively in both spaces. In this
perspective dual citizenship stems from political participation in both
political communities, which brings to light multiple membership and to
some extent multiple loyalties: to the home country, to the country of
residence, and to the transnational community itself. Dual citizenship
becomes the institutional expression of and the basis for
transnationalism.
Transnationalism is important in relation to European integration.
Citizens and residents participate in the European Union's politics
through transnational networks combining identity—be it national,
religious, or both—and interest. This is also due to the very nature of
the European Union, where the idea of supranationality has given shape
to a transnational civil society within which networks of solidarity
(national, regional, religious, or professional) compete, interact, and
cover the European space. The politicization of each of these networks
has led to the formation of transnational, de-nationalized public space.
In this space, thanks to the density of communications between actors
from different traditions, transnational communities can socialize
politically and the same actors can learn the trade of a new political
culture that takes shape outside the nations and their institutions,
creating a new political identification that is de-nationalized and
transnational. The identity of a transnational citizenship is expressed
through the fight of transnational actors for equality and human rights,
seeking at the same time a unified identity in search of legitimacy
before supranational institutions. Paradoxically, a unified identity for
a transnational community leads to a particularity that becomes the
basis for building a “transnational nation”: non-territorial and its
nationalism translates the transnationalization of communitarian
feelings.
Transnationalism and Europe raise the question of territoriality with
regard to participation and citizenship.4
See the Introduction of M. Berezin, in M. Berezin and M.
Schain (2004).
First of all,
transnational organizations create a space for political participation
that goes beyond national territories. They re-map a “political
community” that is Europe, albeit transnational and therefore
de-territorialized and/or re-territorialized. From this perspective,
territory becomes a broader, unbounded space, where nation-states and
supranational institutions interact, and where transnational networks
build bridges between national societies and Europe (
Kastoryano 2004). As for citizenship, it implies, in the
view of the activists involved in building such a network, a role of
responsibility in the construction of a new “community of faith”
5 In reference to Otto Bauer.
that
is supposed to represent the European Union and is expressed by the
“will to live together.”
6 Inspired by E.
Renan's famous phrase “Qu'est-ce qu'une nation?” “What is a
nation?”
Just as it was at the formation of a national
political community, this implies the expression of their will to live
together on a
de facto multicultural (including residents with
legal status) and democratic space (Kastoryano
[1998]
2005;
2002b).
The question of European citizenship has led to the elaboration of
concepts such as postnational, cosmopolitan and/or transnational
membership, and constitutional patriotism, all concepts that came along
with the Treaty of Maastricht in 1992. These concepts remain, however,
normative. In legal terms, the Treaty defined the status of “citizenship
of the Union.” According to Article 8 of the Treaty, a “citizen of the
Union” is whoever holds the nationality of one of the member states. In
principle, citizenship of the Union requires the national citizenship of
one of the member states. Thus the Treaty maintains the link between
citizenship and nationality as is the case in nation-states. But the
practice of citizenship of the Union brings an extra-territorial aspect
into play with regard to nation-states: again Article 8 (8a–8d) of the
Treaty gives the citizen of the Union, the right to move, reside, and
work freely in the territory of a member state as well as the right to
vote and run for office in local elections and in European Parliamentary
elections based on residency (i.e., in the territory of a member state
of which he or she is not a citizen, but just resident). The
extra-territoriality of the concept of citizenship is expressed by its
practice, that is, political participation beyond territorially limited
nation-states, therefore de-territorializing the national community or
re-territorializing the European space. As Preuss (1998) has pointed out, territoriality becomes the basic
means of the citizenship of the Union.
Extra-territoriality is precisely what gives transnationalism its
strength. Like dual citizenship, it institutionalizes multiple
allegiances and dissociates citizenship from nationhood and
territoriality. Within the European Union this multiplicity of
allegiances and spaces for political participation include the home
country in the repertoire of citizenship. In fact, European citizenship,
as a more global concept of membership than nation-states, introduces
the allegiance of immigrants to their home country into the bargaining
process in the same way that they express their allegiance to their
state of residence and to the transnational community in which they are
involved. The countries of origin participate in building a
transnational community and encourage extra-territorial citizenship. For
example, countries like Turkey, Morocco, and Pakistan, in relation to
their émigrés settled in Europe, have changed their citizenship laws,
introducing dual citizenship in their constitutions in order to maintain
emigrant loyalty by inducing them to maintain their original
citizenship. Even though such processes can be sources of tension
between home and host countries for countries that reject dual
citizenship, the home country contributes openly to the construction of
a “diaspora” and, contributes to the design a “diasporic identity” that
is expressed by the attachment of its citizens—former or current—to the
homeland. Such extra-territoriality is at the core of transnationalism.
It keeps the legality of the citizenship of the country of origin, but
only on its territory; its de-territorialization abroad becomes a
resource for identity and mobilization for individuals and/or groups of
immigrant descent. Within this perspective the nation is linked to the
citizenry of the home country.
At stake is the integration of the state (both states) into a global
space (Ong 1999, specifically Chapter 8). Take
the case of Turkey, for example. Four million Turks have settled in
different European countries to form a new category called “Turks
abroad” by the Turkish authorities and the media. The Turkish government
aims to maintain the attachment of the émigrés to national
ideologies—secular, expressed by official rhetoric on Kemalism, and at
the same religious—by insuring a permanent allegiance to what is called
“moderate Islam” by national official circles as well as the
international media as a reaction to Islamism developed in immigration.
Turkey's goal is to maintain national citizenship values abroad; it is a
way of sustaining the link between citizenship and nation, but
extra-territorially. In other words, external to the nation, external to
the territory, but yet a citizen. In this case, at stake is Turkey's
place in the European Union. Such a “de-territorialized” belonging
nourished by the Turkish state constitutes a resource for negotiations.
For countries of settlement, at stake is the inclusion of transnational
activities into the national community and the “re-territorialization”
of nationhood. Generally speaking, transnational nationalism supported
and entertained by states has become an inevitable issue in
international relations.
* * *
Could transnationalism give shape to a new form of nationalism that
differs from the highly territorialized nationalisms of the 19th and
20th centuries? Transnational communities are constructed around shared
references and bring to the fore a feeling of belonging to a
“deterritorialized nation” with identity claims that are nourished by
new expressions of nationalism. Together, they lead to a redefinition of
the link between territory, nation, and political space, challenging the
nation-state as well as a territorially-defined political structure.
But transnationalism and an extra-territorial citizenship generate
negotiations between transnational actors and states. For transnational
actors, a transnational action becomes a political tool leading them to
act from “outside.” For states, transnationalism is a way to include
identity issues developed in a minority situation into their political
strategy and “re-territorialize” them or themselves act as
“de-territorialized” actors in order to maintain the loyalty of
transnational actors and of any nationalist expression beyond their
political border. It becomes for states a way to integrate into the
process of globalization.
Thus the paradox: Even if transnational logic and its expression of
nationalism try to circumvent national politics and weaken the state,
the state remains the driving force of the process of globalization.
Despite its limited autonomy due to normative pressures of supranational
institutions, despite an increasing interdependence between the internal
and external in political decisions, the state remains the main actor
for negotiations defending its interest and its sovereignty within and
outside of its borders. It remains the legal source for citizenship
despite dual citizenship. But transnational communities and their
“nationalization” have become an important source of identification,
resistance, and mobilization, a source of power stemming from the
mobility of individuals and groups in opposition to the immobility of
states. Therefore, couldn't the de-territorialization of citizenship
generate new tensions between states and communities and, more
generally, new tensions in the international system?
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