Abstract

This article demonstrates how the Conservative system of social protection in Germany has been converging toward the Liberal American model during the past two decades, focusing on social protection for the unemployed and pensioners. In addition to public/statutory provisions, occupational welfare is also covered. Despite an overall process of convergence, we continue to witness stark dissimilarities in the arrangements for social protection outsiders: whereas Germany continues to constitutionally guarantee a legal entitlement to minimum social protection for all citizens, such a guarantee does not exist in the United States. The lack of such legal entitlement for poor people of working age, combined with the criminalization of the "dangerous class," is a key differentiating characteristic of the US model at the beginning of the twenty-first century. The findings confirm but also qualify Franz-Xaver Kaufmann's analysis of the United States as "capitalism," which lacks collective welfare responsibility for all citizens, as compared to Germany's "welfare state."