majority to be in more natural accord with the genius of the French system. We shall see reasons for believing that this method is most consistent with obtaining the best results from popular government everywhere.

Outside of Paris all the communes and cities of France are regulated by the law of 1884, the members of the municipal council varying from ten to thirty-six, Lyons alone having fifty-four, as Paris has eighty. The members are elected on a general ticket or, where the larger - cities are divided into sections, on a general ticket for those sections. The municipal suffrage may now be exercised by every Frenchman who has attained his majority, has lived six months in the commune, and has not lost his civil rights and privileges through the commission of a crime or other disqualifying acts. Thus universal suffrage in France means almost precisely what the same term signifies in the United States, except so far as in the latter educational requirements are concerned.

Having elected their municipal councillors, the voters have performed their one chief task. They have conferred upon a chosen body of their fellow-citizens the right to exercise all the powers which are by law reposed in the municipal organism. The council proceeds without delay to choose from its own membership the mayor and his so-called adjuncts or assistants. These are all appointed for the full term of four years. The mayor is the presiding officer of the council and the executive head of the municipality. His range of duties is wide and responsible. He assigns various administrative tasks to his adjuncts. . . . The council itself also appoints a number of standing committees for the consideration of important subjects, or the general oversight of particular departments. All these committees have the mayor as nominal chairman, although the actual duties of the chairmanship are usually performed by one of the adjuncts, who is assigned to act in the mayor's stead.

In England the council, on the recommendation of the standing committees, makes all appointments of municipal officers and employees, while in France the mayor exercises the entire appointing power, except as regards certain offices which the law specifically requires to be filled in some other way. The British mayor is merely the presiding officer of the council, holding his place for only one year,

and possessing no administrative authority or power of appointment. In the French, as in some American municipalities, the mayor is the executive head, with powers and duties which would seem to give him almost the position of a dictator. The sharp distinction, however, between the French and American systems lies in the fact that the French mayor is not only a member of the council and the council's presiding officer, but that he and his adjuncts owe their appointments entirely to their fellow-councillors.1

In the United States, though the mayor is elected by the people, the council in practice holds his power through confirmation of his appointments and the initiative in finance. In France the same result is obtained by the election of the mayor by the council. Though this result has not been fully worked out, Mr. Shaw sees it impending :

If I am not mistaken in the tendency of things, as the system actually acts in France, the real influence of the council is increasing at the expense of that of the mayor. It could not well be otherwise where the council is composed of active and intelligent men. The standing committees must inevitably grow in influence, and the adjuncts in the course of time must, it would seem to me, find themselves in very much the same position as the chairman of the chief committees of an English council. The mayor, under the French system, will doubtless long continue to be intrusted with the general oversight and control of the executive work of the commune; but I am not disposed to believe that he will always hold so dominant a place as the law of 1884 seems to contemplate. Experience will soon begin to show how far the French councils, without any changes in the law, will be able to make the mayor practically their obedient servant in the performance of his executive function.2

As the mayor and the adjuncts, as well as the council, are chosen for four years, the force of popular control is very limited, and still more so by the fact that both mayor and council are in a great degree under restraint by the prefect, and through him by the central government. It cannot be called what is known as local self-government in the United States. Still it approaches more nearly to 1 Op. cit., pp. 173-175. 2 Op. cit., p. 175.

it than any other in Europe, which may furnish grounds for Mr. Shaw's remark:

If I were to venture upon a dangerous comparison, I should be disposed, after asking that due allowance be made for numerous exceptions, to entertain the view that in the present decade the French councils have been less susbtantial and responsible bodies than those of the large English and German towns, while far superior in these qualities to those of American cities of corresponding size.1

In Belgium, up to 1893, the property qualification for voters limited the proportion to one in thirteen of the adult males, or one in fifty of the population. Even the law of 1895 disfranchises in municipal elections every man under thirty, requires three years' residence, gives a second vote to married men above thirty-five and paying from five to fifteen francs taxes as householders, and a third vote to those who derive a revenue of at least a hundred and fifty francs from real estate. These things "give assured control of municipal affairs to the well-todo classes." If we add that the council is chosen for six years, renewable in fractions, and that the mayor for an indefinite term and his assistants for six years are appointed by the general government from the members of the council, it is evident that the conditions are too different from anything in the United States to make comparisons of any value. The same may be said of the Dutch system, with its electors limited up to 1887 to three in one hundred inhabitants and since to one in fifteen, its council chosen for six years, and its mayor or burgomaster appointed by the sovereign for the same term.

The Italian cities are governed under the general law of 1889, which is too recent for predictions of its ultimate working. The voters include practically every male citizen twenty-one years old who can read and write; but as fully fifty per cent. of the males of voting age are illiterate, the 1 Op. cit., p. 180.

VOL. II-I

electors are still only one person in eleven or twelve. The municipal council ranges from fifteen persons in communes of less than three thousand inhabitants to eighty in cities having more than two hundred and fifty thousand. They are elected one-fifth each year for five years upon general ticket, a provision which distinctly encourages class manipulation against the popular will. The council elects a giunta or committee of from two to ten persons for two years, and a sindaco or mayor for three years; the last two authorities holding the real executive power. The council seems to fill somewhat the function of the New England town meeting; that is, a criticising instead of a legislative body grasping at executive power. What is said of Milan, however, is typical of the real difference between all European city governments and those of the United States.

It is pleasant to be assured that in all the vigorous activities which mark the municipal government of Milan the foremost citizens take the leading part. The giunta is composed of men of the best qualifications, who, as a rule, possess wealth, and are glad to devote themselves to the affairs of the community. In a word, the aristocratic element is in executive control. The council contains its more popular elements, but is representative of the best classes in the town. It has its sprinkling of active business men, lawyers, architects, and engineers, but, taking municipal government as a whole, it seems to be chiefly in the hands of the "old families," and it certainly commands the best talent that the city affords. Reëlection of councillors is quite usual, and the yearly municipal election, at which sixteen of the eighty council seats are filled, is seldom attended with much excitement. Thus, in the election of 1892, the number of voters registered on the municipal electoral rolls being 44,594, there were only 14,177 votes actually cast, and this would appear to be an average election.1

It will readily be understood that there is not much affinity between German methods of administration and those in this country. Admirers of Prussian rule can have but little to hope for here, and however much the

1 Op. cit., pp. 265, 266.

French Revolution may have modified practice there has been no definite break since the time of Frederick II. The three-class voting system of Berlin is sufficient to eliminate popular control, while the six-year term of the municipal council is more than sufficient to extinguish popular interest.

It would not have been possible in the Germany of Stein and of Frederick William III. to establish representative institutions upon a basis of popular equality. The Prussian system emphasized the property qualification, and that system remains to-day.

The voters are those who pay certain kinds of taxes above the minimum amount, and this restriction excludes perhaps ten or fifteen per cent. of the men of voting age. So far as the voters are concerned their one task is the selection of a good municipal council. Everything in the life of the gemeinde revolves about this one central body. It finds the burgomaster, designates his expert associates of the magisterial coterie, supplies the means for carrying on the city government, and represents in its own enlightenment, ability, and aspirations the standard and the character of the community's progress.

Stability in the German municipal councils is secured by partial renewal. Thus the councillors of Berlin and the Prussian cities are elected for six years, and one-third of the seats are vacated and refilled every two years. Taking the German cities in general, the most usual period for which councillors are elected is six years, with the plan of renewal in three instalments.1

The organization of other German cities differs only in detail from that of Berlin. It is perfectly evident that no city council in the United States does or will resemble anything of the kind here described.

While the working of popular government in France is much more like that in the United States, it is natural that we should turn in preference to Great Britain for a comparison.

At first sight it may seem strange that while any appeal to the example of the English national government is received in this country with jealousy and contempt as un-American, contrary to our institutions, and a servile

1 Op. cit., pp. 307, 308, 309.