1 ACCOMMODATION OF MUSLIM RELIGIOUS PRACTICES IN EUROPE Theory and practice Gouvetas Demetrios The approaches taken by Western European countries to the way they treat their Muslim minorities range from aggressive efforts at assimilation, to policies that border on benign neglect and that often have resulted in the marginalization of this community. In order to answer to the question, why states have responded differently to the religious needs of Muslims we should engage a cross-national approach. Muslim citizens and permanent residents in these countries share nearly identical goals: they want to build mosques for public worship and religious schools to transmit the faith, and they want the state to make the concessions necessary so that they can practice their religion. What is different across Western European states is how states have responded to those religious concerns. France, exercising a policy that has its roots in the French Revolution of the late 18th century, which was driven by a belief that a set of universal values ("liberty, equality, fraternity") could be applied to everyone, is one of the most activist states in this regard, as it has pursued a vigorous policy of assimilation through its educational and other institutions, aiming to create Frenchmen from the country's largely North African immigrants and their offspring. According to many native French, that set of values, combined with the country's highly regarded traditional culture, are supposed to make assimilation irresistible to newcomers. The United Kingdom, on the other hand, has adopted a more multicultural model. Its' policy focuses on getting immigrants to accept Britain's core institutions and to learn English, rather than changing them into Englishmen. As Soper1 says "...I think they've found a good balance because they're doing much better than most other countries in Europe. Muslims in Britain are making more progress in business and politics than they are most elsewhere." 1 Joel Fetzer and Christopher Soper, Muslims and the State in Britain, France, and Germany (Cambridge: University of Cambridge Press, 2005) 2 By far the majority of European countries, including Germany, Italy and Spain, have, at least until recently, taken a third, more laissez faire approach. This kind of policy seems to treat Muslim minorities as a temporary phenomenon that will eventually go away and hence can safely be ignored. Until 2000, the rhetoric of German politicians was full of references to (Muslim) minorities as guest workers, no matter how long they had been living and working there, and "guest" implied temporary. Germany until then based its citizenship laws on jus sanguinis, or blood, rather than jus solis, or place, as is the case in the United States, making it difficult for Turks and other immigrants who were not ethnically German, as well as their children and grandchildren born in Germany, to acquire citizenship. In 2000, the country overhauled its naturalization laws, making those born in the country, regardless of ethnicity, eligible for citizenship, and easing citizenship requirements for other longtime residents. However, this new law is not by itself enough to make a significant part of native German population to accept that Germany is an immigrant country, an acceptance already made by the politicians. Germans have yet to come to grips with the presence of a permanent non-German minority. In the wake of 9/11, all of Europe's governments, as well as their people, have taken much greater notice of the Islamic communities in their midst. Indeed, the fear of terrorism, reinforced by the Madrid and London bombings and the attacks in the Netherlands, has prompted some of these states to pursue a more assimilationist model of integration. In Denmark, for instance, the government banned arranged marriages, still popular among many Muslims. Even in multicultural Britain, civics classes and a loyalty oath were added as requirements for citizenship. The results of this transformation are also evident on Muslim organizations. According to Nielsen, "the pressure imposed on Muslim organizations by European official, legal, political and bureaucratic expectations is such that Islam has to become and ethnic identity".2 Before examining the theories that explain the variety of ways of state accommodation, it is necessary to point out, who constitutes a Muslim. Shahid 2 Jorgen.Nielsen, Muslims in Western Europe (Third Edition. Edinburgh University Press 2004) 3 and Köningsveld3 , classify Muslims under four categories, according to degrees of religious convictions: * confessionals "who are practicing believers and who regard Islam not as a religion but also as a socio-cultural way of life"; * believers "who accept the religious and socio-ethical principles of Islam without observing the specifically religious obligations"; * liberals "who attach great value to many ethical and philosophical aspects of Islam, but at the same time are critical of or even reject many of the religious aspects, especially in the socio-political sphere"; * and agnosticists "who do not believe in the Islamic articles of faith and reject religion as a basis of socio-cultural life in general." Indicators of religiosity among Muslims worldwide and non-Muslims in the United States and Western Europe (WVS 99-01)4 % Importance of Religion ("somewhat" or "very important") % At least once monthly attendance at religious services % Describe self as a religious person % Belong to a religious organization Muslims Worldwide 85 48 90 5.5 (71.5)* Non-Muslims United States 83 61 83 58 Non-Muslims Western Europe 47 31 63 32 Western Europe combines data from France, Britain, Germany, Italy, Netherlands, Denmark, Belgium, Spain, Ireland, Norway, Sweden, Portugal, Luxembourg and Austria. * Value in parentheses is for Muslims resident in Western Europe. 3 W.A.R Shahid, and P.S. Van Köningsveld , Religious Freedom and the Position of Islam in Western Europe (Kampen Kok Pharos Publishing, 1995) 4 Source : WVS (World Values Survey [computer file]). 1999-2001. Ronald Ingelhart et al. [producer]. Inter-university Consortium for Political and Social Research [distributor]. 4 Theories of State Accommodation Tariq Ramadan claims that "Muslim integration into the fabric of Europe will have three main strands straightforward taking-on of citizenship, involvement in society and politics at all levels, and the demand for financial and political independence".5 Three theories have been employed, aiming to explain state accommodation of Muslim minorities religious practices: * Resource mobilization theory, which focuses on the political resources of Muslims, as the determinant of success in achieving concessions. * Political opportunity structure theory, which emphasizes the role of political institutions in creating the fertile ground for each group's political activism. * Ideological theories, which claim that national ideas about citizenship, nationhood and assimilation primarily determine state response. On the other hand, we should also emphasize the influence of church-state relations, which explains the particularities of relations between states and Muslim minorities. Political Resource Mobilization theory According to the resource mobilization theory, the political resources of Muslims, determine the extent of concessions generated by the governments of the host countries. Effective organizational structures, wealth channeled into these organizations to further political agendas of the group, and successful leadership, knowledgeable of the political system are some aspects of these political resources, which are necessary for mobilization of groups and securing desired policy outcomes. An examination of the organizational degree and leadership of European Muslims would easily indicate that there is lack of "resources necessary to bargain effectively with the state, a situation closely related to the failure of Muslim groups to obtain desired policy outcomes."6 5 Tariq Ramadan, "Who Speaks for Europe's Muslims?" Le Monde Diplomatique (12 June 2000): 1 6 Fetzer and Soper , 8 5 This argument has extensive merit, for: - Islam is characterized by its personal-faith framework, which, in contrast with Catholicism for example, does not sanction the authority of a single voice, leading to issues of legitimacy of leadership and, at the end, to a natural lag for Muslims as new comers to adapt to the political system. - European states have adopted strict neutralization rules, allowing only a small percentage of Muslims to vote. Of course, political activism does not require citizenship, however a non-voting interest group always finds it extremely difficult to convince politicians to support its demands. - Moreover, heterogeneity is likely to challenge group cohesion despite shared problems and demands. Generally, "the absence of native-born clergy and group leadership almost certainly means that Muslim groups lack key resources, particularly information about how best to use the political system to their advantage".7 Nevertheless, as Muslims are becoming more and more experienced, and under the growing pressure, caused by the necessity for problems to be resolved, they gradually develop viable methods to deal with the above stated issues. According to Klausen, "Muslim leaders often identify themselves with... the 'new line' in European Muslim politics... described as a focus on national politics, a new emphasis on Muslim unity irrespective of ethnic and religious differences, certain expectations about professionalism and 'playing by the rules' of national political discourse."8 Trying to explain a state's policy on Muslim religious rights, by analyzing domestic political considerations and the relative power of parties and movements that support Muslim religious rights against those that oppose them would involve focusing on the origin, ethnic composition, and organizational patterns of Muslim communities, within a particular nation state. These descriptions accent the role of resources in mobilizing Muslim groups in Western Europe and stress the organizational structures which link individuals into a social movement. It is evident that the Euro-Muslim organizations' action has been characterized by political ineffectiveness, due to lack of resources, necessary to 7 Fetzer and Soper, 9 8 Jytte Klausen, The Islamic Challenge: Politics and Religion in Western Europe (Oxford: Oxford University Press, 2005) 6 bargain with the state. The Muslims have failed to create really representative organizations at national levels, which would manage to promote their interests and could force the governments to respond to their political demands: " Muslims in most Western European states have thus far been unsuccessful in creating representative organizations at national levels, which can function as spokesman for the Muslim communities with the respective government".9 The existence of ethnic, religious, national and linguistic divisions should be noted, since one of the defining characteristics of this minority group is its heterogeneity, which seems to be acting as a barrier to their political mobilization as, in the UK for example, where they are divided by nation of origin (India, Pakistan, Bangladesh, and Arab countries), major branches of Islam (Sunnism, Shiism) and Islamic schools of thought (Deobandis, Barlewis and Wahhabism), Muslims have organized several political organizations, none of which has ever managed to become an effective national group. Hence, it may be misleading to take Muslims in Europe as a single unit of analysis for any given policy issue. For even within one country, "...Muslims are not a unified constituency. Ethnicity, gender, political outlook, and class are sources of disagreement and dissent"10 . In France, majority of the Muslims are of North African descent with complicated colonial history, whereas in Germany, Turkish guest workers and their families have been the most prominent wave of immigrants. In the United Kingdom, on the other hand, most Muslims are highly educated citizens from former Commonwealth countries; i.e. today's Pakistan, India, and Bangladesh. One of the most important consequences of this diversity, is its complicating effects on the bargaining power of Muslim minorities to further their policy demands from the state as a single constituency. The weakness caused by the ineffectiveness of their political representation becomes even worse, given their failure to produce a native-born leadership. The fact that, in France for example, an estimated 95% of all imams come from abroad, and that the percentage in other West-European countries is similar, as long as religious leaders in other Western countries are concerned, the 9 Shahid and Köningsveld, 3 10 Klausen, 52 7 absence of native-born clergy and group leadership means that Muslim groups lack key resources, especially information. Besides, some analysts11 argue that there might be something endemic in the structure and ideology of Islam itself, something that makes the mobilization extremely difficult. It is true that there is no counterpart in Islam to a Christian church, no formally instituted body to supervise the religious and political agenda, and no religious hierarchy, especially among the Sunnis. A comparison between the politics of Muslim and Jewish groups in Britain would lead to interesting conclusions: Jewish groups have been much more effective, gaining concessions, since they have three significant political resources, generally absent in the Muslim community: communal unity, coherent organizational resources, and the strategic placement of communal personnel in elite positions. Political Opportunity Structures theory According to the second theory, the main reason for the impotence of the Muslims to force the governments to respond to their demands, has to do with the system itself constraining or facilitating group actions, with the political institutions. The capacity of the Muslim groups to engage in collective action is being influenced through direct and indirect ways, by the state officials and institutions. The main characteristics, upon which the Muslim groups' effectiveness depends, are whether it is a unitary or a federal polity, the type of electoral system, the separation of powers between the executive, legislative and judicial branches of government and the position of key political elites. Evidently, strict neutralization rules, legislation on minority rights, antidiscrimination laws, and even laws designating the recipients of welfare, directly impact the prospects for the social, economic, and political status of Muslim minorities, and inevitably, the prospects for securing accommodation for their religious demands from the state. To take one example, because of very different citizenship laws in the two countries, a much higher percentage of British 11 Carolyn Warner "Organizing Islam for Politics in Western Europe" (Paper prepared for presentation at the annual meeting of the American Political Science Association, Atlanta, Georgia,1999): 5 8 Muslims are citizens than are German Muslims, which is translated in much more political opportunities. The institutional structure itself can also surely influence the political activism of groups. In France, for example, where there is significant concentration of power, these groups find it much more difficult to bargain, since they have to do it at a national level. They are obviously aiming for national legislation to win concessions, while in Switzerland, with the federal political system, Muslims find it much easier to mobilize at a local level, where their power is concentrated, and they have gradually been able to win more policy victories. Generally, there is a direct connection between the institutionalization of the immigrant culture and what the host country's legal system allows. The same goes for the electoral system, and the incentives and electoral pressures which are exercised during the planning of the public policy. Ideological theory The way the state resolves issues related to immigrant rights, and especially to religious ones, is also being shaped by the nation's political ideology. This ideology is mainly constituted by ideas about citizenship, nationality, assimilation and pluralism, that determine state response. The strong connection between ideology and political practice towards the Muslims is evident, comparing the dominant ideologies in France and Britain. France's culturally particular idea of what it means to become a French citizen led the elites to oppose separate Islamic institutions, due to the state's ideological commitment to integrating individual outsiders. In France it is the republican ideals of the concept of citizenship as well as laicism that accounts for the state response to religious demands of minorities. At the same time, the British dominant political ideas place greater emphasis on managing relations among divergent populations, and allow these groups to retain their identities. Both of the major parties have been recognizing Islamic immigrants through public policy, and as a result, the British state has supported multicultural education, separate Islamic schools, race relations' 9 legislation and the development of independent Muslim communities. At the same time, the British realistic, pragmatic political tradition, guarantees preference to practical policies, instead of abstract theorizing. Attitudes among citizens of Western democracies toward Muslim residents Country % of public that regards immigration from MENA* a "bad thing" for society % of public reporting a "favorable opinion" of Muslims % of public that regards relations between Muslims and Westerners "generally good" % of public that regards Muslims as "respectful of women" % of public that perceives a conflict between Muslim piety and modern society France 41 65 33 23 26 Germany 59 36 23 17 70 Spain 33 29 14 12 58 UK 32 63 28 26 54 US -- 54 32 19 40 * Middle East and North African countries. The three theories described above, explain, to a point, the different approaches of state accommodation of Muslim religious practices by the Western European countries, and indicate the various reasons for the failure of these religious minorities to promote decisively and achieve effectively their goals. These three factors obviously interact with each other and define the social and political environment, into which the European Muslim has to fight for the satisfaction of his religious needs: Ideology ­ State (Political Opportunity Structures): The state institutions' structure is shaped by ideology. Laws, which constitute political opportunity structures within which Muslim minorities have to function, are the institutionalizing organs of ideals such as republicanism and citizenship. Results of this interaction are the requirements for admission to the political community. 10 For example, as Kastoryano says,12 marriage or period of residence, 'good moral character' and knowledge of the French language and culture from living in the society, are required in France. Meanwhile, Sweden has allowed dual citizenship since 2001, in order to help immigrants in Sweden, many of whom are not able or willing to renounce their original citizenship, to have a better chance at integration by becoming Swedish citizens. Resource Mobilization ­ Muslim Minorities: Effective organizational structures, wealth, successful leadership, and group cohesion, are aspects of political resources of the Muslims, qualifiers of their minority as an interest group. Institutional Framework of Islam ­ Muslim Minorities: Islam, especially Sunni Islam is shaped by an institutional framework which does not sanction a hierarchical clergy or an established church. Scholars who are specialized in subjects of Islamic law, can by no means be considered as authoritative figures, as their ideas and interpretations have minimum influence on Muslims, especially those in the West. This personal-faith framework raises issues of leadership legitimacy within the Muslim minority group, making it more challenging to negotiate with the state as a unitary actor represented by a designated body or an individual. Muslim Minorities ­ State (Political Opportunity Structures): Together political resources and the institutional framework of Islam influence effectiveness of Muslim minorities to bargain with the state. However, Muslim minorities have to function within the political opportunity structures, such as the neutralization laws, which determine what rights immigrants or asylum seekers have, and how easily immigrants or descendants of immigrants can become citizens. Another example is the regulations for organizations: for instance, in France even though Muslim organizations would not be recognized under religious criteria, there are roughly 1000 associations run by Muslims, registered by the law of 1901 because of their cultural activities at local level. However, in order to fully analyze the phenomenon of Muslims' state accommodation, we should also take into consideration the Church-state relations, and combine this factor, maybe the most important one, with the other three. 12 Riva Kastoryano, "Citizenship: Beyond Blood and Soil" in Leveau (eds.), New European Identity and Citizenship, (Burlington: Ashgate Publications, 2002): 17 11 Church-State Structure ­ State (Political Opportunity Structures): Laws institutionalize Church-state relations, constituting political opportunity structures. For instance, in countries with a concordat, such as Spain and Germany, states recognize certain religious groups and extend them privileges such as public funding for schools and tax exempt status. Fetzer and Soper13 suggest that conflict over the headscarf and school curriculum in France is merely the product of that country's "long and contentious state-church history"; similarly, they find that "inherited state-church institutions best explain how Germany has accommodated Muslims". Ideology ­ Church-State Structure: In exactly the same way, ideology, such as laicism, shapes the institutionalization of church-state relations. Church-State Structure ­ Muslim Minorities: Established church-state relations set the institutional framework within which Muslim minorities have to function . The cases of the United Kingdom, France and Germany The presence of a formal religious establishment, the Church of England, shapes state accommodation in Britain . One would might think that the activity of an established, dominant, official religion, playing such an important role, would be translated into a barrier to Muslims as they negotiated with the state over contested religious practices . On the contrary, the British model of church-state relations been a major factor of institutional organization, political motivation and ideological expression for Muslim activists , rather than leaving Muslims out of the policy mix of state benefits. British church-state policy makes significant allowances for religious groups and, as a consequence, resources flow to religious schools and social service agencies14 . "Because they are more likely to be citizens, British Muslims have myriad political opportunities for activism at their disposal. They can, for instance, participate through conventional political channels (voting 13 Fetzer and Soper : 94, 126 14 S.Monsma, and J.C.Soper, The Challenge of Pluralism: Church and State in Five Western Democracies (Lanham, Maryland: Rowman & Littlefield Press 1997) 12 and running for elective office), and existing parties have an incentive to make direct electoral appeals to them".15 Most importantly, the presence of an established church encouraged Muslim groups to look to the state for a public recognition of their religious rights and public policy needs. In other words, the establishment of an official religion sets the example for Muslims to bargain with the state on their religious issues. According to Nielsen, "...access to citizenship, legally speaking, and access to political participation in Britain is easy. Germany, and, above all, Switzerland are examples of the opposite end of the scale". (Jorgen S. Nielsen, April 2003).16 Although "policy statements made by prominent politicians seeking votes usually ignore the negative impact on the minorities whose votes are not deemed worth seeking"17 in Britain, where the Muslim community is older and has enjoyed recognition in more positive terms, instances of the Muslim community-political parties or representatives is more directly observable. At the same time, Muslims no longer vote blindly, but for those politicians and parties that specifically address the issues of concern to their group. As the previous British MP from Birmingham wrote, "Anxious immigrants who throw themselves on the mercy of their members of parliament are now a minority. Their children and grandchildren will only vote for politicians who explicitly meet their demands...Muslims expect something approaching a personal relationship with their members of parliament. They demand audible and visible support particularly in face of the fashionable suspicion of all things Islamic"18 Muslim politicians themselves are also changing, since they do not wish to present themselves and be voted for as Muslims, but rather as regular politicians. They appeal to their voters' support for their capabilities as political leaders of their entire constituency, not just its Muslim members. Sadiq Khan, MP from Tooting in the UK, uses these words to describe himself: "I am a Tooting, boy and 15 Fetzer and Soper, 12 16 Jorge Nielsen, Speech presented at the "Muslims in Europe Post 9/11" conference at St Antony's College (Oxford, 23-24 April 2003) 17 Nielsen, 2004: 126 18 Roy Hattersley, "I took the Muslim vote for granted, but that has all changed" The Guardian (8 Apr 2005) 13 man. I was born in the constituency and I have lived there all my life. I married a Tooting girl..."19 . The case of France is completely different, as lacité is the ideal that dominates in the French public sphere. Separationism between religion and state is the ultimate rule, and the French policy on state accommodation of religious practices could do nothing but serve as a certain version of that separationism . Not only secularists, but even most practicing Christians, Jews, and Muslims still justify their respective positions by appealing to some version of this particularly French concept. Cesari, argues that "Lacité refers to the uneasy compromise that French people have made between the letter of the law of separation of state and church and its peculiar implementation within French culture. Quite paradoxically, when passed in 1905, the law's primary intention was not to champion religious freedom per se in France. Rather, it was to weaken Catholic influence by putting Catholicism on an equal footing with religious minorities within the public domain. Practically speaking, confirming to the law meant confining religious belief to the private sphere. Ideally speaking, conformity meant and still means extirpating homage to religious values from all spheres: personal, familial, social, cultural, and political. Through the decades, major religious groups-Christian and Jewish- have made uneasy peace with la cit by relegating religious expression to private domains. Muslim settlement in France has disrupted that peace. It has introduced new confusion over boundaries between public and private space and led to renewed controversy over religious freedom and political tolerance"20 . According to Fetzer and Soper (2005:62-97)21 , lacité could be divided into two broad categories: strict (a.k.a. militant or closed) and soft (also called pluralist or open). According to the first version of lacité, French citizens may, in their private life, believe what they will about religion . However, lacité sets several restrictions to religious individuals, when the public sphere is concerned. Praying in public, refusing to eat certain kinds of food in a school cafeteria, and wearing religiously distinctive clothing or jewelry outside the home, for example, 19 Khan Sadiq, Maiden Speech House of Commons Hansard (23 May 2005) 20 Jocelyne Cesari "Islam in France: The Shaping of a Religious Minority" in Haddad (eds.), Islam in the West: From Sojourners to Citizens (New York: Oxford University Press, 2002) 21 Fetzer and Soper, 62- 97 14 all violate the first type of lacité, and generally they are not allowed to engage in any exterior manifestation of their religion. According to the soft version of lacité, the state should respect all religious beliefs but also foster the free exercise of religion by, for example, funding private religious schools. Far from wanting to confine religion to the private sphere, advocates of open lacité wish to encourage interreligious understanding and public dialogue among different religious groups, even in the public schools. As both a form of public policy and an ideological tradition, lacité has structured the political arguments of Muslim groups and political leaders in France. Muslims in France find themselves contesting rearguard actions on highly symbolic, though still very significant, issues such as the right of girls to wear the ij ~b in state-run schools. At the same time, Muslims have not, been able to put on the policy agenda such things as support for separate Islamic schools or state aid for Muslim social service organizations, both of which are viewed as simply unacceptable given the state's supposed commitment to church-state separation. The pre-existing church-state model in France, therefore, restricted Muslim efforts successfully to negotiate with the state on substantive religious issues of concern to their religious community. Jennings22 identifies four characteristics of French thought on the subject of immigrant integration: 1) integration of immigrants must be in accord with the secularism of the state; 2) it is individuals rather than groups that integrate 3) integration presupposes rights and duties 4) immigrants and the French must be treated equally. Perhaps the most important of these is the notion that individuals may integrate, but not groups: in a republican democracy, groups are not to be differentiated as such, and indeed the targeting of nationals of a particular country is only likely to bring about dreaded communautarisme Separation between church and state also exists in Germany, however not in the way it does in France. German Basic Law establishes that separation formally, but at the same time the Constitution secures cooperation (particularly strong for the historically dominant and state-supported Roman Catholic and 22 Jeremy Jennings "Citizenship, Republicanism and Multiculturalism in Contemporary France," Bristish Journal of Political Science (30:4, 2000): 583 15 Evangelische churches, which together represent over ninety percent of Germany's religious population) between the two institutions in such areas as education and social welfare provision23 24 .It seems that the German church-state system strikes a middle ground between Britain's established church and France's lacité. State schools in Germany provide formal religious instruction (Religionsunterricht). Moreover, churches that are recognized by the state as public corporations are eligible the proceeds of a church tax (Kirchensteuer) that is collected by the government, and the state runs a significant portion of its social welfare services through agencies of these publicly recognized churches. The question, however, is whether the state will expand its informal religious establishment to include Islam. The German federal system, not surprisingly, leads to large differences in how or whether public schools provide instruction on Islam. Educational policy is the responsibility of Land governments and in some Länder, such as Berlin and North-Rhine Westphalia, teaching about Islam has been included in the state school curriculum. Other states have even financed separate Muslim schools. Of course, not all Länder have been so accommodating to Muslim demands, and no German Land has yet granted public corporation status to a Muslim group. "German Muslims...cannot as effectively participate through conventional politics, parties have limited reasons to make appeals to them, and they face the threat of deportation if they engage in unconventional political activism."25 Cem Ozdemir (the first ethnic Turk to be elected Member of Parliament in Germany) claims authorities have ensured their political incapacity: "Voters of Turkish origin are not seen as one group with common interests. They are more or less ignored by the two main parties (the Christian Democrats and Social Democrats), and they have failed to organize themselves to speak with one voice"26 . Despite these setbacks, the German church-state model legitimates Muslim demands for state accommodation of their religious practices and creates 23 Gerhard Robbers "State and Church in Germany" In Gerhard Robbers, editor, State and Church in the European Union. Baden-Baden: Nomos Verlagsgesellschaft 24 Grace Davie, Religion in Modern Europe (Oxford: Oxford University Press 2000) 25 Fetzer and Soper, 12 26 Cem Ozdemir, 24 Nov 2005 16 opportunities for the political mobilization of Muslim groups around discrete public policy issues. At the same time, as Kastoryano27 notes, "Germany stands today as one of the most liberal states in Europe with regard to citizenship." The public incorporation of Muslims in the three countries can be interpreted as a path dependent process shaped by the constitutional and legal patterns of church-state relations in each country as well the history of countryspecific arrangements that have been worked out over time between religious groups and the state. The result has been policy divergence, as states have responded to Muslim demands in light of the countries' unique legal, historical, and constitutional structures. Pre-existing church-state practices have shaped the contours of the debate in unique ways in each of the three states. This maturing Muslim community has moved beyond being an immigrant population in search of better immigration laws and working conditions, and toward demands any minority makes: education, socio-economic benefits and equality in rights. As Tariq Ramadan28 put it, "These new Muslims may be European, but they are still Muslim. And they are upsetting the old lines of demarcation - they are not like the old Muslim leaders who were so docile and so little nuisance". (Tariq Ramadan, June 2000: 3). They may identify with their respective ethnic community more than the religious one, but even then it is more often the case that they wish not to be perceived as solely an exponent of that group: "I'm not going to deny my roots. But I see myself primarily as a Dutch politician, with special antenna into the Turkish community", the Dutch Muslim politician Coskun Coruz said.29 A systematic opposition to the secular state seems to be confined to a relatively small group among Muslims living in Europe, whereas the majority of Muslims have apparently been able to adapt quite well to the secular political order. However, "Secularism is becoming a religion: banning crucifixes, banning headscarves...The whole idea behind state secularism is that everyone should 27 Riva Kastoryano, Negotiating Identities: States and Immigrants in France and Germany (Princeton: Princeton University Press, 2002) 28 Tariq Ramadan, 12 June 2000: 3 29 Washington Post (24 Apr 2005) 17 have the same rights. But if secularism restricts someone's identity then it's going to be against this principle"30 . State-Religion Relations in 15 EU Members31 Established Religion State Funding of Churches Religious Instruction in Public Schools Austria NO NO Optional Belgium NO YES Optional Denmark Lutheran YES Optional England Anglicanism YES Obligatory Finland Lutheran and Orthodox YES Obligatory France NO NO NO Germany NO YES Obligatory Greece Orthodox YES Obligatory Ireland NO NO Obligatory Italy Catholic (signed a concordat) NO Optional Luxemburg NO YES Obligatory Netherlands NO NO Optional Portugal Catholic (signed a concordat) YES Optional Spain Catholic (signed a concordat) YES Optional Sweden NO YES Optional 30 Hassan El Araby, Swiss Muslim politician, 25 Apr 2004 31 Sources: Gaillard 2004; U.S. 2004; Baubérot 1994c. 18 Conclusion: The Future of Islam in Western Europe Attempting to distinguish the role that Islam could play in Western Europe, Fetzer and Soper see three possible scenarios. These scenarios are public policy secularism, pan-religious mobilization, and political backlash against Muslims. Scenario #1: Public Policy Secularism A secular tide will move religion and the state further apart. Church membership will decline and the religious belief will be limited to the private sphere. The state will remove itself from the business of recognizing churches and granting to them any statutory advantages (Iverson 2004)32 , since very few citizens will be actively religious, and the inherited church-state links will be abandoned by the politicians, due to the continuously increasing political disputes around religion. Scenario #2: Pan-Religious Mobilization A political coalition will be formed by European Christians, Muslims, and Jews, aiming to protect the very idea that the state should accommodate or aid religion. Secularism will be seen as a generalized challenge to all religionists, as a common threat, since the denial of religious instruction to one group will call into question the benefits of all the others. In the same view, the realization that Christians and Muslims share common interests and face a common enemy (secularism) could lead to political alliances, that are now considered impossible. The fact that European Muslims are more socially conservative than the general European population, embracing a set of mores on such issues as abortion and homosexuality closer to the traditional values and family agenda of the churches, 32 Hans Raun Iverson, "Religion in the 21st Century" Dialog: A Journal of Theology 43 (Spring 2004): 28-33 19 particularly those of the Roman Catholic Church hierarchy, makes possible that Muslims and Christians might join forces politically to oppose further secularization of public policy. Euthanasia, decriminalization of narcotics, and the further sexualization of public spaces are all issues that have the potential to create this kind of pan-religious mobilization, that would drew together two religions with centuries of conflict history. Scenario #3: Political Backlash Against Muslims The electoral success of nativist political parties in France, the Netherlands, Austria, and even Britain will set the example for a generalized emergence of an islamophobist wave. The terrorist attacks by Muslim extremists over the past several years have clearly tested the region's faith in multiculturalism. The large Lyon mosque has been attacked at least three times, once with bullets, once with a Molotov cocktail, and once with paint in the French national colors. Such attacks are hardly rare in Western Europe. The current wave of anti-Muslim hostility probably has not yet peaked in Western Europe33 , and the war on terrorism continues. 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