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The Limits of the Liberal State: Migration, Identity and Belonging in

Europe

Fiona B. Adamsona; Triadafilos Triadafilopoulosb; Aristide R. Zolbergc

a
International Relations at the School of Oriental and African Studies, University of London, b Political
Science, University of Toronto, c Political Science, New School for Social Research, New York
Online publication date: 16 May 2011

To cite this Article Adamson, Fiona B. , Triadafilopoulos, Triadafilos and Zolberg, Aristide R.(2011) 'The Limits of the

Liberal State: Migration, Identity and Belonging in Europe', Journal of Ethnic and Migration Studies, 37: 6, 843 859
To link to this Article: DOI: 10.1080/1369183X.2011.576188
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Journal of Ethnic and Migration Studies

Vol. 37, No. 6, July 2011, pp. 843859

The Limits of the Liberal State:

Migration, Identity and Belonging in
Europe

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Fiona B. Adamson, Triadafilos Triadafilopoulos and

Aristide R. Zolberg

What are the contemporary limits of the liberal state with respect to immigration,
citizenship and the rights of ethnic and religious minorities in contemporary Europe? The
papers in this special issue of the Journal of Ethnic and Migration Studies examine how
recent developments in Europe raise new questions regarding the relationship between
liberalism, migration, identity and belonging. In this introduction, we identify three
major themes that run through the papers in the issue*the use of liberal norms by states
for exclusionary purposes; the possibility of the emergence of illiberal liberalism; and the
extent to which identity politics and policy-making may be increasingly transcending and
transforming the limits of the liberal democratic state in Europe. After briefly presenting
these three themes, we summarise the arguments of the individual authors and suggest
possible directions for future research.
Keywords: Liberalism; Migration; Citizenship; Boundaries; Integration; Europe
Contemporary developments in Europe raise complex and challenging questions
regarding the limits of the liberal state with respect to immigration, citizenship and
the rights of ethnic and religious minorities. Whereas it has regularly been assumed
that liberal norms and identities foster greater inclusion, openness and pluralism with
respect to migration policies and minority rights, a number of events suggest the
Fiona B. Adamson is Senior Lecturer in International Relations at the School of Oriental and African Studies,
University of London. Correspondence to: Dr F.B. Adamson, Dept of Politics and International Studies, SOAS,
University of London, Thornhaugh Street, Russell Square, London WC1H 0XG, UK. E-mail: fa33@soas.ac.uk.
Triadafilos Triadafilopoulos is Assistant Professor of Political Science at the University of Toronto.
Correspondence to: Prof. T. Triadafilopoulos, Dept of Political Science, University of Toronto, 100 St George
Street, Toronto, Ontario M5S 3G3, Canada. E-mail: t.triadafilopoulos@utoronto.ca. Aristide R. Zolberg is
Walter P. Eberstadt Professor of Political Science at the New School for Social Research, New York.
Correspondence to: Prof. A.R. Zolberg, New School for Social Research, 6 East 16th Street, New York, NY
10003, USA. E-mail: arizol@newschool.edu.
ISSN 1369-183X print/ISSN 1469-9451 online/11/060843-17 # 2011 Taylor & Francis
DOI: 10.1080/1369183X.2011.576188

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844 F.B. Adamson, T. Triadafilopoulos & A.R. Zolberg

need to re-evaluate such assumptions. What are we to make, for example, of the
decision of French authorities to deny a Moroccan womans naturalisation
application because she wore the niqab?1 In its ruling upholding immigration and
social service officials initial 2005 decision, the Conseil dEtat stated that the
applicants decision to wear the niqab constituted a radical practice of her religion
(and) behaviour in society incompatible with the essential values of the French
community, notably the principle of equality between the sexes (Crumley 2008). The
proliferation of similar bans on religious attire in public spaces, restrictions on
speech, mandatory integration courses, citizenship tests and controls on the
admission of spouses through amendments to family reunification policies*all
defended on the grounds that they further liberal ends*suggest the need for a closer
interrogation of the relationship between liberalism, migration, identity and
belonging in contemporary Europe.
The papers brought together in this special issue of JEMS take up this central task
of exploring and untangling the boundaries of identity and belonging in the liberal
state in Europe. The authors in this issue employ a mix of empirical, normative and
legal analyses to make sense of the changing landscape of migration and integration
policy. In so doing, they contribute to an emerging area of debate and research on
changing migration and incorporation policies in European states (Guild et al. 2009;
zc u ru mez 2008). Collectively, the papers raise a
Joppke 2007a; Schmidtke and O
number of challenging questions for further exploration. When, for example, does
the deployment of liberal norms become an illiberal practice? What are (and should
be) the symbolic boundaries of identity, belonging, membership and community in
liberal democratic states? Has liberalism replaced nationalism as the ideology of
belonging in Europe, and how do and should states respond to ideas, practices or
politics that can be interpreted as illiberal? Moreover, does it indeed make sense to
even discuss such issues with reference to individual states*or do the boundaries
and limits of contemporary identity politics, as well as state policy-making, now both
transcend, quite literally, the physical and policy-making limits of the liberal state?
As a prelude to the analyses in the individual papers that follow, we briefly discuss
here some of these key themes, situating them in broader scholarly debates. We focus
on discussions regarding the exclusionary nature of liberal norms, the question of
when liberalism becomes illiberal and the changing nature of boundaries in liberal
states. We then turn to a short summary of the individual papers before making a few
concluding remarks.

Liberal Norms as Exclusionary?

The migration studies literature has traditionally conceptualised liberal norms as key
factors in producing open migration policies, fostering integration and securing
migrants rights (i.e. Freeman 1995a; Hollifield 1992; Soysal 1994). Yet states in
Europe increasingly appear to also be deploying liberal norms as boundary-markers
that delimit and demarcate the symbolic borders of the state. Liberal norms, it seems,

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Journal of Ethnic and Migration Studies

845

may in some cases be replacing or supplementing other boundary-markers, such as

ethnic or civic nationalism, in shaping migration and integration policies in
European states.2
In many respects, this trend stands in marked contrast to assumptions regarding
policy-making in the post-WWII period. The literature on postwar immigration and
citizenship politics has emphasised the opening up of liberal states to previously
excluded groups, through the renunciation and replacement of racially discriminatory admissions policies (Joppke 2005a; King 2000; Tavan 2005; Triadafilopoulos
2010); the expansion of foreigners rights to family reunification (Hansen 2009;
Soysal 1994); and the relaxing of rules governing residency, the provision of civil and
social rights and the acquisition of citizenship (Carens 2002; Hammar 1990; Hansen
and Koehler 2006; Hansen and Weil 2001; Jacobson 1996; Jacobson and Ruffer 2003;
Joppke 1999; Howard 2009; Soysal 1994; Weil 2001). That states are using liberal
norms in an exclusionary fashion thus presents a challenge to much of the literature
on immigration and citizenship politics and policy-making.
How are we to understand these developments? Some might argue that they simply
represent a shift in the immigration cycle (Brubaker 1995; Freeman 1995a, 1995b)
or, alternatively, that they are primarily a reaction to a specific set of real or imagined
security threats (Hampshire 2009; Tsoukala 2005). Such policies could also be viewed
as an extension of the increasingly hostile approaches taken by liberal states to
asylum-seekers and undocumented migrants in the 1980s and 1990s. These policies
have often been explained by reference to the influence of extreme-right-wing
parties*political actors whose adherence to liberal principles, however, is questionable (Angenendt 2003; Betz 2003; Givens 2005; Messina 2007; Minkenberg 2001,
2002; Zaslove 2008).
The deployment of liberal norms in an exclusionary fashion could represent a
populist turn in European migration and integration policy*in effect a
democratising of policy-making in this area in ways which reflect popular sentiment
rather than entrenched interest groups, thus shifting what is considered to be
legitimate public discourse on migration (Brubaker 1995; Freeman 1995a; Guiraudon
and Joppke 2001). Arguably such developments could also be interpreted as symbolic
of a deeper transformation of state identity and community boundaries away from
nationalism and towards the notion of civilisational identities of which liberalism
then becomes a key tenet (Huntington 1996).

Illiberal Liberalism?
Not surprisingly, the challenge of understanding these developments has prompted
a lively debate. While some see the deployment of liberal norms*such as gender
equality*as a ploy for pursuing and extending long-standing exclusionary
programmes based on deeply entrenched racist mindsets (Fekete 2006; Razack
2008), others note that their support among progressive actors is novel and
therefore worthy of more sustained analysis and explanation. Bans on religious attire

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846 F.B. Adamson, T. Triadafilopoulos & A.R. Zolberg

in public spaces can be squarely situated in a republican or secular liberal tradition

(Barry 2001; Bowen 2008; Laborde 2002). The deployment of liberal norms can be
viewed as a fundamentally progressive development, designed ultimately to protect
and safeguard basic liberal values of liberty, equality and tolerance in European
societies. Or, alternatively, such developments can be viewed as symptomatic of the
rise of a new form of illiberal liberalism that draws boundaries against its illiberal
others in a fashion that fundamentally undermines core principles of pluralism and
tolerance (Kostakopoulou 2010; Tebble 2006; Young 2002: 425).
This debate is not wholly new, of course. Critics of liberalism have always pointed
to its inherent contradictions, and the intimate relationship between the historical
development of liberal thought in Europe with empire, colonial domination and
racial hierarchies (McCarthy 2009; Mehta 1990, 1999). In a series of important books
and articles, Christian Joppke (2005b, 2007a, 2007b, 2009, 2010) has amended his
views on the intrinsic openness of the liberal state in diagnosing the causes of what he
has variously termed regressive liberalism and civic integrationism. According to
Joppke (2007a: 268), recent trends warrant a Foucauldian reading of liberalism which
emphasises its power and disciplining aspects. This reading forces one to engage with
a deeply rooted repressive strain in liberal thinking. Joppke cites John Stuart Mills
1859/1974) approval of the use of illiberal means to achieve liberal goals as evidence
of how this strain can be seen as stemming from liberal theory itself.3 In a similar
vein, Adam Tebble (2006) argues that the use of exclusionary immigration and
integration policies reflects a distinctive mode of liberal nationalism*identity
liberalism*which rejects multiculturalisms emphasis on compromise and accommodation in favour of a more definitive assertion and defence of distinctively liberal
ways of life.
Both Joppke and Tebble note that new modes of liberal exclusion are indicative of
shifts in liberal theory and practice and not simply manifestations of racism, although
their effects often are*and are intended to be*exclusionary. As such, they echo and
build on Veronika Stolckes (1999) claim regarding the distinctiveness of contemporary exclusionary rhetoric and practice (see also Gilroy 2000). What Stolcke
referred to as cultural fundamentalism has arguably been shaped into a distinctively
liberal fundamentalism that does not target foreigners per se, but rather particular
subsets of immigrants or minorities whose religious/cultural practices or political
demands are deemed incompatible with liberal ways of life. This targeting is reflected,
for example, in the deployment of integration and citizenship tests, perhaps the most
notorious of which was the German state of Baden-Wu rttembergs interview guide
(Gespra chsleitfaden) for ascertaining the values of citizenship applicants from Muslim
countries (Joppke 2010; Prantl 2006). According to Joppke (2010), policies along
these lines seek to particularise universalism by demanding that membership in the
liberal state be reserved exclusively for liberal people. Making good on this demand
compels the liberal state to regulate the motivations and internal dispositions of
so-called suspect groups. It is precisely when liberal states move from regulating
individuals outward conduct to enquiring into and authoritatively prescribing

Journal of Ethnic and Migration Studies

847

internal dispositions that liberalism becomes regressive and illiberal. Joppke (2009)
maintains that European states distinctive forms of liberalism explain variation in the
degree and intensity of illiberal liberalism in Europe. In so doing, he appears to
contradict his earlier (2007b) claim that the trend toward civic integrationism had
made any talk of national models of immigrant integration redundant. These
tensions in Joppkes work suggest that there is still much to be done in making sense
of contemporary shifts in liberalism as it relates to issues of immigration and
integration policy in Europe.

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The Boundaries of the Liberal State

Examining the limits of the liberal state encourages us to pay closer attention to the
role that boundaries play in defining contemporary liberal democratic states. Such
boundaries can be symbolic and discursive, but may also call into question the
relationships that exist between the territorial, identity, governance and policymaking dimensions of the European state. It is instructive that European states are
rethinking their criteria for naturalisation and incorporation of migrants at the same
time as they are facing what could be termed a boundary crisis that is both symbolic
and literal.
Immigration and incorporation processes always raise the issue of group
boundaries of identity and belonging (Alba 2005; Korteweg and Yurdakul 2009;
Lamont and Molnar 2002). The state has historically used immigration policy as a
tool in fostering a particular national identity (Triadafilopoulos 2010; Zolberg 2006),
balancing its pursuit of economic and strategic interests against concerns of national
integration and social cohesion (Adamson 2006; Chin 2009). Zolberg and Long
(1999: 89) note that boundary-crossing, boundary-blurring and boundary-shifting
all represent possible patterns of identity negotiation in migration contexts, in which
the redeployment of liberal norms as boundary-markers rather than principles of
inclusion could be viewed as a form of boundary-shifting that is occurring in
European states*with the blurring of racial, ethnic and religious boundaries through
such developments as anti-discrimination legislation (Joppke 2007a)*accompanied
by the simultaneous emergence of a bright boundary of membership based on liberal
criteria.
The challenges of setting the symbolic and discursive boundaries of belonging in
Europe are compounded by additional boundary challenges that are increasingly
relevant for understanding the limits of the liberal state. The greater openness of these
liberal states has allowed for the emergence and thickening of transnational fields
and social spaces, which temper the importance of territoriality both in scholarly
analyses of migration and in migrants lived experiences (Basch et al. 1993;
Bloemraad et al. 2008; Faist 2000). Meaningful transnational identities*whether
national, religious or ideational*may include political identifications that transcend
the physical boundaries of the state (Adamson and Demetriou 2007). How might
liberal states react to actions on the part of their residents*citizens and non-citizens

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848 F.B. Adamson, T. Triadafilopoulos & A.R. Zolberg

alike*that signal allegiance, political or spiritual, to extra-territorial authorities and/

or communities? In some contexts, the boundary negotiations occurring within
particular national contexts may also mirror broader negotiations and contestations
that occur within a geopolitical context. In this sense, they are not merely national
negotiations, but are tied into larger global circuits of power and identity. Within the
UK, for example, identity claims and political demands made by Muslims are often
articulated using language that evokes a broader geopolitical context of British
foreign policy and US hegemony. The liberal state may be viewed not simply as a
domestic arena for identity negotiation, but as a component of a broader geopolitical
structure of liberal hegemony (Adamson 2005). Similarly, Muslim political demands
articulated within a domestic context may also reference debates and discourses that
emerge within the broader context of a transnational Muslim public sphere.
The challenge faced by liberal democratic states is therefore how to reconcile liberal
principles and identities that transcend the state (Soysal 1994) with competing
principles or sources of authority which also transcend it. An example of this type of
conflict would be the liberal principle of equality under the law, with demands for the
recognition of a plurality of legal frameworks within the liberal state. Such questions
have, of course, been the staple of long-standing debates on multiculturalism and
communitarianism. Jonathan Laurences (2006) work on the incorporation of Islam
in contemporary European liberal democracies suggests that concerns regarding
religious transnationalism among Muslims (encouraged in part by European
receiving states tendency to leave the spiritual needs of immigrants to sending
countries and/or Muslim states claiming authority in religious matters) is leading
European states to forge formal consultative links to domestic groups representing
Muslims. Here transnationalism has provoked noteworthy and consequential
boundary shifts featuring the adaptation of existing corporatist institutions
regulating churchstate relations to better capture the realities of societies
transformed by postwar immigration. In a similar vein, Matthias Koenig (2007)
has demonstrated that global human-rights norms have pushed European states to
extend religious rights previously reserved for Christians and Jews to Muslim
immigrants. Here an unbounded, broadly encompassing logic of appropriateness
has provoked shifts in domestic institutions and practices in a more-or-less
inclusionary trajectory. These examples of integrative boundary shifting stand in
stark contrast to the more exclusionary tendencies pointed out in discussions of
illiberal liberalism, suggesting that approaches to integration may be informed by
quite distinctive logics, ranging from corporatist/problem-solving to partisan/
political.
These various challenges point to the tenuous nature of the identity boundaries of
the liberal state in an age in which territorial nationalism is increasingly being
challenged (Wimmer and Glick Schiller 2002, 2003). The importance of territory is
being called into question, for example, in the emergence of external integration
measures in which some European states are administering integration tests abroad
(Guild et al. 2009: 914). This can be viewed as an extension of the remote control

Journal of Ethnic and Migration Studies

849

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border policies of the 1990s (Guiraudon and Lahav 2000; see also Torpey 2000;
Zolberg 1997). At the same time, questions relating to the boundaries of membership,
identity and belonging are being raised in a period marked by shifting boundaries of
policy-making and governance, as regional institutions are increasingly involved in
shaping migration and incorporation policy at the state level. With the transfer of
immigration policy competence to the EU in 1999, the issuing of the EU Race
Directive in 2000, and the emergence of the EU framework on integration that
produced a set of Common Basic Principles for Immigrants Integration in 2004,
aspects of policy-making in liberal democratic states in Europe are now increasingly
being delegated, at least in part, to Brussels (Guild et al. 2009; Joppke 2007a;
Thielemann 2008).

Summary of Articles
The papers in this special issue of JEMS employ a mix of analytical, normative and
legal reasoning to contribute to these emerging debates and areas of research. In
developing their arguments, the contributors draw on a wide range of perspectives
and literatures, including comparative politics, sociology, political theory, international relations and EU law. The papers collectively explore the contemporary policy
challenges and contexts with which liberal states are grappling; examining what
liberal states are doing empirically in terms of policy and, in some cases, what they
ought to do if they are to live up to their status as liberal states and achieve their
policy objectives. Hence, the articles in this issue contribute both to recent empirical
work on migration and integration politics and more-philosophically oriented works
on multiculturalism and the so-called limits of toleration in contemporary liberaldemocratic states.
Not surprisingly, given the variety of disciplinary and philosophical perspectives
the authors bring to their work, the range of diagnoses and prescriptions vary*at
times quite widely*making for a lively exchange of ideas and interpretations. Here
we briefly summarise the main arguments of the authors in this issue before
concluding with some thoughts as to how research on the limits of the liberal state in
the spheres of immigration, integration and ethnic and minority rights in Europe
might move forward.
Triadafilos Triadafilopoulos argues in the next article that the turn to a more
aggressive civic integrationism among European states is based on a complex
confluence of factors, including the breakdown of the postwar economic order and
consequent hollowing out of welfare states, the dissolution of party systems and the
rise of new parties of the Left and Right, the end of the Cold War, the deepening and
expansion of European integration and the emergence of the so-called war on terror,
which has emphasised civilisational distinctions based in part on religious differences.
Triadafilopoulos argues that these factors form a backdrop for the emergence of a
distinctively Schmittian liberalism, which rejects multicultural accommodation and
compromise and seeks instead to protect liberal publics from migrant groups whose

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850 F.B. Adamson, T. Triadafilopoulos & A.R. Zolberg

unfamiliarity with liberal values and putatively illiberal practices calls for either their
full assimilation into liberal ways of life (through integration courses and bans on
religious attire and practices) or outright exclusion, either at the border (through
more stringent admissions policies, especially as regards family reunification) or into
the citizenry (through rigorous naturalisation tests). Triadafilopoulos notes that,
while some manifestations of Schmittian liberalism may be consistent with certain
strands of the liberal tradition*indeed, they are a logical outcome of perfectionist
approaches taken to their extremes*they are not likely to be helpful in terms of
furthering integration and social cohesion. As Triadafilopoulos concludes, Schmittian
liberals risk alienating the very groups they seek to integrate*turning potential
friends into enemies. Thus, he calls for integration policies that are consistent with
liberal-democratic values but also respectful of deeply held differences and open to
dialogue and mutual accommodation.
Randall Hansen next offers a competing perspective in his contribution to the
debate. Drawing on survey data on Muslims in Britain and France, he argues that
European states must reconsider the particular form of liberalism they embrace, if
they are to harness immigration in a manner consistent with their interests. With
regards to the economy, Hansen notes that overly generous Continental European
welfare states have tended to integrate immigrants into welfare rather than work,
leading to unemployment rates among immigrants [that] are at best double the
national average and, at worst, over three times it. He therefore counsels a laissez faire
direction, as represented first and foremost by the United States, so that immigrants
are given greater incentives to enter the labour market. According to Hansen, [t]he
solution for Europe...is a bit of tough love: reduce or remove welfare benefits for
migrants, and make it clear to them that they are welcome, but that their welcome is
contingent upon their willingness to enter the labour market.
With regard to identity, Hansen rejects liberal multiculturalism, arguing that it
weakens bonds of commonality among immigrants and members of the host society.
He recommends instead that European states adopt more assertive, self-confident
expressions of national identity modelled after the French republican tradition, as
doing so will provide immigrants with a clearer sense of what the society they are
joining holds up as its core values. While the freedom of religion remains deeply
embedded in liberal states practices, it should be limited to the private sphere and
granted to individuals rather than groups*with special exemptions and accommodations granted only in rare circumstances. The broader public sphere should be
governed by civic mores and clear expectations, reinforced by state power where
necessary.
Fiona Adamsons article also examines the relationship between Muslims and the
liberal state in Europe. She examines the growing use of Muslim as a category by
both Muslims and state authorities in Europe. Placing contemporary domestic
debates surrounding Islam in Europe in a broader geopolitical context, Adamson
argues that the emergence of Muslim identity politics in European states cannot be
understood only as a domestic-level development internal to states, but must also be

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851

seen as deeply connected with geopolitics and with broader debates and discourses
that are occurring in globalised Muslim public spheres that extend beyond the state.
Focusing on the variety of Muslim political organisations operating in the UK,
Adamson points out that the deployment of the political identity category of
Muslim vis-a`-vis the liberal state can be used by different actors for different
purposes. On the one hand, there are groups such as the Muslim Council of Britain
(MCB) that can be viewed largely as a standard interest-group*an umbrella
organisation that presents itself as primarily interested in collective claims-making,
lobbying and interest representation on behalf of British Muslims seeking to secure
their rights to exercise religious freedom. On the other hand, a group such as Hizb
ut-Tahrir uses the category of Muslim as a means of asserting a political identity that
stands in opposition to the liberal state. This group has explicitly juxtaposed a
Muslim identity with a British or Western variant and has, at times, publicly
encouraged British Muslims to reject liberalism, disengage from institutionalised
participation in British politics, and instead identify themselves primarily with a
broader global ummah in the form of working for the re-establishment of a global
caliphate. While a group such as Hizb ut-Tahrir represents a minority perspective, it
nonetheless provides an explicit example of a form of illiberal politics which liberal
states must then respond to*with some liberal states banning such a group
(as Germany did in 2003) and others accepting it as one amongst a multitude of
competing voices that are expressed as part of free debate in a liberal states civil
society.
Erik Bleichs article examines this dilemma in greater detail by exploring the limits
of free speech in liberal states. Tracing liberal states approaches to the regulation of
hate speech and hate crimes since World War II, Bleich argues that liberal states are
capable of enacting and enforcing laws that limit the freedom to be racist while
maintaining liberal principles of freedom of opinion and freedom of expression. The
slow creep that has typified policy development in this area reflects states efforts to
balance respect for freedom of speech with [v]alues such as community cohesion,
public order [and] human dignity. This value shift is a distinctively post-WWII
phenomenon, rooted in liberal states reactions to the horrors of Nazism, the
emergence of human rights norms, and the discrediting of racism. Bleich notes that
liberal states particular approaches to the regulation of racist speech and conduct
differ; while most European states have implemented laws against forms of racist
speech such as incitement to racial hatred and Holocaust denial, the US has bucked
this trend by elevating the value of free speech over protections against racist
language. However, as Bleich goes on to note, the US has also introduced laws that
penalise racially motivated crimes, such as assault and battery, despite their potential
to infringe on freedom of opinion and expression. This distinctive feature of the
American approach has been picked up by some European countries and especially
by Great Britain, where policy-makers explicitly drew on legislation introduced in
the US.

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852 F.B. Adamson, T. Triadafilopoulos & A.R. Zolberg

While Bleich sees the regulation of racist speech and conduct as broadly in line
with liberal norms, he fears that recent trends push the limits of this compatibility.
As an example, he notes that the British government has used the war on terror to
justify expanding its laws to cover incitement to religious hatred [while] also
enact[ing] provisions to punish the glorification of terrorism, which could prohibit
statements made against racial, ethnic or religious groups that have been the targets
of attacks. The elevation of national cohesion and public order through these laws
may lead to further curbs on speech. In another case, Frances efforts to outlaw
denials of the Armenian genocide may open the door to claimants who want to
establish their victimhood as legally unassailable. According to Bleich, the key to
avoiding such slippery slopes lies in proceeding cautiously, cognisant of the
particulars of the case at hand, the difference between racist expression that incites
violence and stirs up extreme hatred and speech that is merely offensive, even if
hurtfully so.
Gallya Ruffers article focuses on recent debates over family reunification policy, at
both the EU and member-state levels. Ruffer notes that the rationale animating
family reunification policies has changed; whereas family reunification was thought
of as a socially just and practical solution that would enable the integration of
long-term labour migrants in the past, more recently it has been used to shape
cultural integration by limiting access to particular groups of immigrants,
particularly Muslims. States such as Denmark, France, the Netherlands, Germany,
Austria and Britain have introduced provisions ostensibly aimed at preventing forced
and fraudulent marriages and enhancing the assimilability of immigrants through
integration tests and courses to be taken outside the destination country in advance of
admission. Ruffer maintains that such policies are best thought of as means
undertaken by states to weed out undesirable migrants and thus reassert control
over nation-building. This leads to perverse situations where immigrants who hold
citizenship in an EU member-state enjoy rights to family reunification and mobility
that are withheld from Third Country Nationals (TCNs). Efforts aimed at improving
and streamlining the treatment of TCNs at the EU level have been tempered by
member-states insistence on maintaining their sovereign right to guide societal
integration through immigration controls.
Ruffer also notes that European courts adjudication of the rights of immigrants
versus states has been uneven, owing in part to differences in their conceptualisations
of the right to family life. Though subtle, these differences have allowed
policy-makers at the member-state level to justify restrictions on family reunification
that would otherwise be unconstitutional under domestic law. The end result is a
situation where children and spouses face new barriers to their ability to join family
members in European countries. Ruffer maintains that such positions hark back to an
antiquated conceptualisation of membership, unsuited to an increasingly mobile
world. As such, she argues in favour of a very different approach to family
reunification, premised on the recognition that under conditions of migration,
cultures will remain in flux.

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853

James Hampshires article focuses on debates over naturalisation courses and tests,
asking whether demands for evidence of immigrants societal integration on the part
of the state as a precondition for their being granted citizenship are warranted.
Hampshire distinguishes liberal arguments in favour of quick access to citizenship
after a short period of residency to nationalist positions which hold that
naturalisation can only move forward where immigrants demonstrate assimilation
into a national culture. Hampshire notes that the nationalist position is problematic
on both philosophical and empirical grounds. With regard to norms, liberal states
commitment to neutrality makes the imposition of a particular view of the good life
illegitimate: [a] requirement that naturalising citizens assimilate to a thick national
culture amounts to the imposition of a particular conception of the good and is to
that extent illiberal. This commitment to neutrality is also based on the recognition
that life in contemporary liberal states is shaped by the fact of pluralism; thus the
onus is on nationalists to identify a particular national culture which naturalising
citizens could be expected to assimilate into. While there may indeed be a majority
culture, there will also be important areas of disagreement on what the national
culture is and what the principal goals of the nation should be. In short, in pluralist
societies there simply is no consensus about national identity.
Yet, the discrediting of the nationalist argument does not vindicate a minimalist
liberal position. Hampshire maintains that democratic politics depends on citizens
sharing some core competencies or civic skills, including the ability to understand
and interact with each other in a common language. Moreover, flourishing liberal
societies are founded upon liberal citizens who are reflective and self-critical, and who
accept and endorse the public values of a pluralistic and tolerant public culture.
These insights lead Hampshire to endorse a thickening of the liberal position on
naturalisation: while assimilation into a common culture is ruled out, demands that
immigrants demonstrate some knowledge of the host states official language(s) and
the generic liberal values that govern public life are justifiable on liberal grounds.
While immigrants should be expected to take advantage of opportunities to engage in
language and civics training provided by the state, tests should not determine
whether citizenship is conferred. In other words, a normatively defensible liberalism
accepts compulsory attendance in integration courses but looks suspiciously at tests
which can be used to deny access to citizenship.

Conclusion
We trust that the contributions to this special issue of JEMS will provoke further
debate and research on the limits of the liberal state in Europe. In particular, we
hope the collection demonstrates the fruitfulness of interdisciplinary engagement. By
combining insights from both empirical and theoretically oriented literatures, and by
taking perspectives that focus on national policy-making as well as the regional and
transnational context within which liberal states are embedded, we present a complex
and nuanced view of the multiple ways in which boundaries of membership,

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854 F.B. Adamson, T. Triadafilopoulos & A.R. Zolberg

belonging and identity are being renegotiated in Europe with respect to migration,
citizenship and ethnic and minority rights.
As a research agenda, much work needs still to be done to understand the
limits of the liberal state in Europe. States*liberal or otherwise*do not
function as autonomous actors . . . but rather as instruments manipulated by
internal actors who have gained the upper hand in this particular sphere at a
given time (Zolberg 2006: 12); hence, we need to pay closer attention to the
influence of parties, the media, opinion-makers and social movements. Recent
work by Marc Howard (2009) and Erik Bleich (2009) offers stimulating insights
into how distinctively political processes, featuring discreet actors and institutions, may be analysed to better understand liberal-democratic states responses
to immigration- and membership-related challenges.
Secondly, more work needs to be undertaken to explain the variation in particular
states approaches to the regulation of practices, speech and other embodied forms of
cultural difference. Here scholars in the field of migration studies could benefit from
paying closer attention to the contributions of students of social policy, who
emphasise the mediating role of formal and informal institutions (for a good
overview see Amenta 2003). Koenigs (2005) research on varieties of churchstate
relations and their influence on liberal states approaches to the integration of
religious minorities generally, and Muslims in particular, offers a good example of
such an approach. More-ethnographically oriented work also points to the
importance of local understandings in shaping outcomes.
Thirdly, there needs to be a greater level of dialogue between comparative or
single-country scholars of migration and scholars of International Relations and
transnationalism, whose work can help to illuminate broader global trends in, for
example, the structure of global civil society, the role of regional and international
organisations in norm promotion, and in shaping policy-making and policy
outcomes, as well as drawing attention to the geopolitical context within which
national-level debates and policy developments take place. As Peter Gourevitch
(1978) pointed out long ago, domestic politics is embedded in global structures and
processes. Identifying and theorising these linkages will go a long way toward better
understanding trends in liberal states conduct over time in the fields of immigration,
citizenship and integration policy.
Fourthly, and finally, there is the important issue*largely unaddressed in these
papers*of liberalisms lack of guidance with regard to the formulation of admission
policies. Given the steadily growing demand from the developing world for entry to
states in Europe, which is unlikely to abate in the foreseeable future, there must be
some grounds for limiting admissions; and if admissions are going to be limited,
there is a need for selection criteria among the demand. Should liberal states privilege
the entry of temporary foreign workers in a bid to meet domestic needs while
simultaneously creating an indirect mode of international development assistance
driven by remittances, as recommended by economists such as Lant Pritchett (2008),
or should liberal principles counsel that labour migration of any kind be downplayed

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Journal of Ethnic and Migration Studies

855

in an effort to meet the needs of refugees and thus stem the misery of the worlds
most vulnerable individuals and groups? While there have been some important
responses to these questions (see, for example, Carens 1987, 2010; Ruhs and Martin
2008; Zolberg 2010), more sustained attention is sorely needed to both clarify liberal
principles and guide liberal states policies and practices.
Ultimately, we believe that the papers in this special issue of JEMS should
encourage scholars to take more care to combine insights generated by both
empirically and normatively driven research programmes. With some all-too-rare
exceptions, empirically and normatively oriented scholars have tended to ignore each
others insights, preferring to operate on more familiar, specialist terrains. We believe
this is a mistake and hope that the papers in this special issue demonstrate the
benefits of combining empirically and more-normatively driven lines of inquiry. This
will allow for well-grounded theories and observations that also provide direction to
policy-makers grappling with the challenges of immigration and integration in
contemporary liberal-democratic states.
Acknowledgements
We would like to acknowledge the generous support of the Foundation for
Population, Migration and the Environment (PME) in Switzerland for the
sponsorship of the workshop The Limits of the Liberal State: Migration, Identity
and Belonging in Europe at University College London (UCL) in December 2006,
from whence these papers are derived. Additional support was provided by the
School of Public Policy (SPP) at UCL. We are particularly grateful to Sally Welham,
who managed the logistics of the workshop. In addition to the authors included in
this special issue, additional workshop participants and observers*including
zc u ru mez and
Michael Bodemann, Khadijah Elshayyal, Pontus Odmalm, Saime O
Go kce Yurdukal, along with an anonymous JEMS reviewer*provided helpful
comments that informed this introduction and the editing of the special collection.
We would also like to thank the Council of European Studies (CES) for supporting
our grant application to the PME Foundation in the context of the Councils
Immigration Research Group (IRG). Finally, our thanks extend to Jenny Money and
Russell King at the Journal of Ethnic and Migration Studies for their facilitation of this
special issue.
Notes
[1]
[2]

[3]

The much-publicised case of Faizi Silmi, often referred to in the context of banning the
burqa, actually involved the wearing of the niqab (Erlanger 2009).
On ethnic and civic nationalism, see Brubaker (1992, 1998); Greenfeld (1992); Yack (1996).
For an argument espousing the compatibility of liberalism and nationalism, see also
Kymlicka (2001); Tamir (1995).
Despotism is a legitimate mode of government in dealing with barbarians, provided the end
be their improvement and the means justified by actually effecting that end (Mill 1859).

856 F.B. Adamson, T. Triadafilopoulos & A.R. Zolberg

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