Fact check: How does the 22nd Amendment compare to term limits in other countries' governments?

1. Why the U.S. cap was written — history that still shapes debate

The 22nd Amendment was enacted as a direct response to Franklin D. Roosevelt’s four-term presidency, and it explicitly bars any person from being elected president more than twice, establishing a bright-line electoral constraint for U.S. presidents and normalizing two-term service as the constitutional standard ^[1]. Legal commentators have noted the Amendment’s specific wording and its practical effect in modern politics, but they also emphasize open questions about succession loopholes—for example, strategies involving vice-presidential selection or disputed interpretations that could provoke litigation and political crisis ^{[2] [6]}. These discussions reflect the tension between constitutional text and political innovation.

2. How other democracies mirror America — two-term models and similarities

Numerous countries adopt two-term limits resembling the U.S. approach, setting either consecutive or absolute caps on presidential service; examples include Algeria and Angola’s two five-year terms and Argentina’s two consecutive four-year terms, which mirror the U.S. goal of preventing extended personal rule through electoral restriction ^[3]. These systems share an intent: to prevent entrenchment and encourage regular leadership turnover. Where limits are enforced through constitutional amendment or clear statutory rules, they function as a formal institutional check that constrains incumbents and frames electoral competition in predictable cycles.

3. When limits vanish — examples of rollback and consolidation

Recent events show a global trend of rollback or abolition of term limits, notably in Chad, where parliament scrapped presidential term caps enabling indefinite seven-year mandates, and in El Salvador, where congressional reforms removed presidential limits to allow repeated runs by an incumbent ^{[4] [5] [7]}. These changes are frequently justified domestically as stability or continuity measures, but external observers characterize them as democratic backsliding because they weaken institutional constraints and concentrate power in the executive, undermining opposition capacity and checks and balances.

4. Legal creativity and judicial routes — how leaders circumvent constraints

Scholars identify judicial and legal strategies used to erode term limits, especially in parts of Latin America, where courts have applied novel human-rights frames or technical reinterpretations to permit additional terms or wipe prior terms from count ^[8]. Commentators on U.S. law likewise speculate about hypotheticals—vice-presidential selection or contested interpretations of “elected” versus “serving” could produce litigation-heavy confrontations over the 22nd Amendment’s scope, mirroring tactics elsewhere that rely on legal recharacterization to alter term-counts ^{[2] [6]}.

5. Democratic outcomes — what limits (or removal) mean for governance

Empirical observers link the removal or circumvention of term limits to reduced democratic resilience, arguing that indefinite tenure concentrates power, erodes institutional independence, and encourages personalization of the state, as alleged in Chad and El Salvador ^{[4] [5]}. Conversely, well-enforced two-term rules can support transitions and pluralism, but enforcement depends on robust institutions—constitutional text alone does not prevent subversion if legislatures, judiciaries, or security forces are co-opted, a dynamic reflected in international case studies and cautionary analyses ^{[3] [8]}.

6. How U.S. uniqueness and vulnerabilities intersect with global patterns

The U.S. 22nd Amendment stands out because it was an explicit constitutional limitation adopted in the mid-20th century, yet contemporary debate shows it is not immune to creative challenges; commentators highlight that while the Amendment’s language is straightforward, political actors anywhere—including the U.S.—can attempt procedural or legal maneuvers that test constraints ^{[1] [2]}. Comparative cases demonstrate that constitutional text plus independent institutions are crucial; where one element weakens, term limits become vulnerable to erosion regardless of written law ^{[3] [8]}.

7. What to watch next — litigation, legislative change, and international signals

Future flashpoints include court rulings that reinterpret term-counting rules, legislative amendments that alter presidential terms, and executive moves to reshape institutional checks—patterns visible in recent actions across Latin America and Africa ^{[8] [4] [5]}. In the U.S., proposals or maneuvers that aim to circumvent the 22nd Amendment would likely trigger high-stakes litigation and political mobilization, echoing global precedents where legal arguments, constitutional rewrites, or parliamentary votes produced enduring changes to term-limit regimes ^{[2] [5]}.

Conclusion: The 22nd Amendment is a clear two-term constitutional constraint with historical roots and significant symbolic and legal weight, but international experience shows that written limits can be circumvented or abolished through judicial reinterpretation, legislative reform, or political consolidation—outcomes that hinge on the strength of institutions rather than language alone ^{[1] [8] [4]}.