A fiery populist who incites political violence is up against the wife of a president looking to restore their dynasty. Analysts fear that a close contest could result in a repeat of the bitterly disputed poll 16 years ago. It’s election season in a vast country riven by racial tension, religious extremism, rampant inequality, crumbling infrastructure and gun violence that claims 91 lives a day, and no one is expecting a smooth ride.

This is the United States of America, which still bears the scars of a brutal civil war and four presidential assassinations, as an Africa correspondent might see it. I did that job for six years and reported on elections in the Democratic Republic of the Congo, Kenya, Nigeria, South Africa and Zimbabwe, along with a post-election civil war in Ivory Coast. Now based in Washington and travelling in the US, I have witnessed the rodeo of the Democratic and Republican primaries and got a look at how America compares.

It was just as I was leaving Johannesburg in October that the South African comedian Trevor Noah, in his new role as host of the Daily Show in the US, described Donald Trump as the perfect African president. There was, he said, the self-regard of Idi Amin, the repressiveness of Robert Mugabe, the eccentricity of Muammar Gaddafi.

Trump’s demagoguery and gaudy shows of wealth have done little to alter that view in the eight months since. One might add that Hillary Clinton’s marital connection to power has drawn less scepticism than those of Nkosazana Dlamini-Zuma, ex-wife of South African president Jacob Zuma, or Grace Mugabe, wife of the Zimbabwean president, each of whom might lead their countries one day.

Based on my experiences of sweltering in Lagos and freezing in New Hampshire, I would say not all the parallels are negative. In many African countries, democracy still has novelty value – it is only 22 years old in South Africa – so there is an enthusiasm, a thirst for voting that seemed dead in established western democracies until Trump and the Democrat Bernie Sanders came along. I have felt the electricity of thousands of people thronging into sports stadiums and bursting into song at rallies on both sides of the Atlantic.

On a bleaker note, I remember being in Harare, Zimbabwe, watching queues of dozens of voters who, Mugabe’s opposition claimed, had been bussed in from rural areas to skew the outcome. It was also alleged that thousands of people had been disenfranchised by not finding their names on the voters roll. The politician Tendai Biti said: “They have transformed this election from the margin of violence to the margin of error – from the baton stick and machete to the desktop.”

An echo, at least, of America, where cruder methods were replaced by more subtle ways of excluding voters. This year, 17 states will have voting restrictions in place for the first time in a presidential election; 11 of these states will require their residents to show a photo ID, a stipulation that tends to penalise poor, black, Latino and elderly people. In addition, there is the arcane business of superdelegates, caucuses and convention rules under which the person who gets the most votes will not necessarily always win.

In Congo, I witnessed bullets flying, stones thrown, teargas fired and people running in panic. In the US, such scenes appeared to be a thing of the past until Trump. His rally in Chicago was canceled amid ugly clashes, while in Albuquerque, protesters threw burning T-shirts, plastic bottles and rocks at police, who fired back with pepper spray and smoke grenades. The Republican nominee later tweeted: “Great rally in New Mexico, amazing crowd!”

Yet a critical difference in such situations is that the state security apparatus is not intervening to shore up an incumbent regime. While many African countries remain in effect one-party states, America is in effect a two-party state.

The key to it all, perhaps, is term limits and the constraints they put on the cult of personality. Franklin Roosevelt was elected a record four times and died in office, but now US presidents are constitutionally bound to step aside after two. Barack Obama, the son of a Kenyan, told the African Union in Addis Ababa last year: “I love my work but under our constitution, I cannot run again. I actually think I’m a pretty good president: I think if I ran I could win, but I can’t.”

This remark has become even more pertinent since the rise of Trump, which has left many who feel apathetic toward Clinton probably wishing that Obama could indeed run for a third term. But that thinking is how the rot starts. In Burundi, Congo, Rwanda and elsewhere, popularity in the moment is being used an excuse to change the rules. In other countries, there are no term limits: Mugabe has been in power for 36 years. Obama warned the AU: “If a leader thinks they’re the only person who can hold their nation together – if that’s true, then that leader has failed to truly build their nation.”

America also has the benefit of a free press, whereas some African countries are still dominated by state-controlled media, with independent journalists thrown in jail and dissent crushed. Then again, TV networks in particular have been criticised for giving Trump the equivalent of hundreds of millions of dollars’ worth of free advertising. In many African countries, radio is still king.

Louis Picard, professor of public and international affairs and African studies at the University of Pittsburgh, and a sometime visiting professor at Wits University in Johannesburg, says: “Our media is certainly pretty flawed. The visual media is a lot more polarised than it was 15 years go. That said, it’s pretty hard to get thrown in jail just for writing something.”

The 2000 election, in which George W Bush squeezed past Al Gore amid controversy and confusion, shows that America is not immune to alleged vote-rigging. Hypocritical? “There’s more than a pinch of that,” Picard says. “There is a smugness.”

Even the proudly independent judiciary has suffered a blow as Republicans refuse to confirm Obama’s supreme court nominee Merrick Garland. In a speech that might have been given in angst-ridden 22-year-old South Africa, Vice-President Joe Biden warned of a constitutional crisis and said: “The bonds that held our diverse republic together for the last 229 years are being frayed.”

I ask Freedom House, which monitors democracy in many African states, what it makes of the US election. Arch Puddington, its senior vice-president for research, says: “If you want to talk about a system that is open and holds out the possibility for the rise and fall of new candidates and new faces, the US ranks pretty high. There aren’t many countries where Barack Obama could have moved from the back benches to achieve the presidency. Ditto Donald Trump.”

But he adds: “On the other hand, we would certainly take points off America’s score because of the behaviour at Trump rallies. And on money in elections, there is a chronic problem in the US. We disapprove of the massive role of money in the campaign.”

When a Trump-like figure emerges in Africa, fragile state institutions can collapse and relatively new customs and practices be blown away. In America, after more than two centuries of rehearsal, there are settled norms that will bend rather than break. That’s the hope, anyway. Puddington says: “In the US, I’m reasonably confident that Congress and the courts and independent regulatory infrastructure would function in a normal way under a Donald Trump presidency and would prevent him from doing whatever he wants to do.”

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