Presidential v. Parliamentary Systems of Government

In parliamentary systems of government, the head of government can be removed any time that the prime minister or premier loses the confidence of a majority of members of parliament for any reason.

In strong Presidential systems of government (i.e. systems where the President has more policy making powers than those of a primarily symbolic constitutional monarch), including the United States, in contrast, (basically by definition) the head of government does not serve at the pleasure of the legislature, but may sometimes be removed by the legislature in extraordinary circumstances.

For these purposes, I would consider both "Presidential Republics" and "Semi-Presidential Republics" to be strong Presidential systems, but not "Parliamentary Republics", with or without a ceremonial/non-executive President. There are 41 Presidential Republics in the world in widely recognized countries other than the U.S., more than a third of which are in Latin America, and 23 Semi-Presidential Republics (not counting Iran which is closer to a constitutional monarchy).

Impeachment In The United States Is Only For Cause

In the United States, the process of removing a President is called "impeachment" and Article II, Section 4 of the United States Constitution provides that it is only permitted for cause, stating:

The President, Vice President and all civil officers of the United States, shall be removed from office on impeachment for, and conviction of, treason, bribery, or other high crimes and misdemeanors.

This is somewhat less restrictive than it seems, because the courts have determined that what constitutes "high crimes and misdemeanors" is a "political question" not subject to judicial review. See Nixon v. United States, 506 U.S. 224 (1993) (concerning a judge with the surname Nixon, not the former President of the United States).

But, a legislator is sworn to uphold the U.S. Constitution. See U.S. Constitution, Article VI (which provides in the pertinent part: "The Senators and Representatives before mentioned, and the members of the several state legislatures, and all executive and judicial officers, both of the United States and of the several states, shall be bound by oath or affirmation, to support this Constitution; but no religious test shall ever be required as a qualification to any office or public trust under the United States.")

So, in theory, a legislator applying the impeachment provisions of the U.S. Constitution has a moral duty, at least, to only remove a President from office via impeachment for conduct that amounts to some sort of crime, even if this duty is unenforceable in practice.

The Question

Are there countries with strong Presidential systems in which, unlike the United States, a supermajority can impeach a President (or undertake some equivalent process allowing a national legislature to remove a President from office mid-term) either without cause, or with a definition of good cause that is far more broadly defined than it is in Article II, Section 4 of the United States Constitution?

I'm looking for any examples of such constitutional or legal provisions, not necessarily a comprehensive list of them.

  • 7
    I am not sure that legislators are limited ethically to impeach only for crimes. The misdemeanors part is implicitly contrasted with crimes, suggesting that it's being used in its sense of "unacceptable behavior." It's not being used to refer to the class of crimes referred to as misdemeanors. That's part of why the courts ruled to grant broad latitude.
    – Obie 2.0
    Jun 6, 2019 at 21:32
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    I've never heard anyone seriously object (at least in legal terms) to the quote by President Ford that 'high crimes and misdemeanors' are: whatever a majority of the House of Representatives considers it to be at a given moment in history. So, I'd challenge your assertion that the US has a high bar for impeachment (aside from the significant political issues with it)
    – divibisan
    Jun 6, 2019 at 21:57
  • 3
    The Premise of your question is wrong. Congress, if it so chose and had the political will to do, could impeach the president on a Wednesday. Jun 6, 2019 at 22:12
  • 1
    @jamesqf That's what I mean: legally, the bar for impeachment is very low. Politically, it's difficult, but Article II, Section 4 doesn't seem to pose a high bar at all, at least in my understanding.
    – divibisan
    Jun 7, 2019 at 15:15
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    @grovkin I am simply curious about how this is expressed and what constitutional and legal norms are associated with the process elsewhere. The U.S. ruleisn't hte focus of my interest at all.
    – ohwilleke
    Jun 8, 2019 at 0:28

1 Answer 1


I've gone through the Wikipedia list on impeachment in different countries. Most of them have at least the requirement that there is criminal, unconstitutional or treasonous behavior.

One exception is Iceland, which does not have such requirements but does require two majorities, not just in its legislature but also among the voters. Article 11 of the Icelandic constitution deals with impeachment (the Althingi is the Icelandic parliament):

The President of the Republic may not be held accountable for executive acts. The same applies to those who exercise presidential authority.

The President may not be prosecuted on a criminal charge except with the consent of Althingi.

The President may be removed from office before his term expires if approved by a majority in a plebiscite called pursuant to a resolution adopted by three-fourths of the Members of Althingi. This plebiscite shall be held within two months from the date of adoption by Althingi of the resolution. The President shall not perform his duties from the time the resolution is adopted by Althingi until the results of the plebiscite are known.

If the resolution by Althingi is not approved in the plebiscite, Althingi shall be immediately dissolved and new elections called.

  • Ooh, I like that the response to a failed plebiscite is new elections. There'd clearly be a disconnect between the members of the Althingi and the populace, so it makes a lot of sense.
    – Bobson
    Oct 2, 2019 at 19:33
  • @Bobson yea, though the three-fourths in the legislature seems pretty steep. Also note that Iceland has a small population compared to the US so it's much easier (logistically) to have a referendum or an election.
    – JJJ
    Oct 2, 2019 at 19:53
  • @JJJ The Althingi BTW is one of the oldest, if not the oldest, continuously operating democratic deliberative body in the world dating from about 1000 CE.
    – ohwilleke
    Oct 3, 2019 at 22:36

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