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===Incomplete separation of power=== {{Undue weight|date=January 2024|section|to=this section by making broad generalisations based solely on one citation, and looking solely at one country's parliamentary system}} According to [[Arturo Fontaine Talavera|Arturo Fontaine]], parliamentary systems in Europe have yielded very powerful heads of government which is rather what is often criticized about presidential systems. Fontaine compares United Kingdom's [[Margaret Thatcher]] to the United States' [[Ronald Reagan]] noting the former head of government was much more powerful despite governing under a parliamentary system.<ref name=Fontaine2021>{{Cite news|title=Arturo Fontaine: "Si se estableciera el semipresidencialismo, a poco andar el pueblo sentiría que ha sido engañado"|url=https://www.emol.com/noticias/Nacional/2021/11/05/1037461/cronica-constitucional-arturo-fontaine-semipresidencialismo.html|last=Valenzuela Manguini|first=Álvaro|date=2021-11-05|access-date=2021-11-07|work=[[El Mercurio|Emol]]|language=Spanish}}</ref> The rise to power of [[Viktor Orbán]] in Hungary has been claimed to show how parliamentary systems can be subverted.<ref name=Fontaine2021/> The situation in Hungary was according to Fontaine allowed by the deficient separation of powers that characterises parliamentary and semi-presidential systems.<ref name=Fontaine2021/> Once [[2010 Hungarian parliamentary election|Orbán's party got two-thirds]] of the seats in Parliament in a single election, a [[supermajority]] large enough to amend the Hungarian constitution, there was no institution that was able to balance the concentration of power.<ref name=Fontaine2021/> In a presidential system it would require at least two separate elections to create the same effect; the presidential election, and the legislative election, and that the president's party has the legislative supermajority required for constitutional amendments. Safeguards against this situation implementable in both systems include the establishment of an upper house or a requirement for external ratification of constitutional amendments such as a [[referendum]]. Fontaine also notes as a warning example of the flaws of parliamentary systems that if the United States had a parliamentary system, [[Donald Trump]], as head of government, could have dissolved the [[United States Congress]].<ref name=Fontaine2021/>
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