The world has watched in horror as US President Donald Trump sets about adopting an authoritarian playbook. To understand popular concern, it is important to see that sort of playbook in practice. Frequently mentioned comparative examples include Orban’s Hungary, Erdogan’s Turkey or Modi’s India, all being liberal democratic societies that have increasingly turned authoritarian. China’s crackdown in Hong Kong offers an overlooked example with striking parallels to the unfolding crisis in the United States.
While teaching human rights and constitutional law for decades at leading universities in Hong Kong I watched in horror as one of the freest, rule of law-based societies in the world—where I routinely spoke out on public affairs—turned into a repressive authoritarian state. In 2020 the city’s top-rated liberal institutions, very much like those in the US, were crushed under a new Beijing-imposed national security law.
Under Beijing’s crackdown Hong Kong transitioned from one of the freest rule-of-law-based open societies in the world to a repressive illiberal order.
Subsequent Beijing impositions and locally enacted laws would further seal the city’s repressive turn. One of the most vibrant societies in the world has now largely gone silent. Over the past few months, you can imagine my shock as I observe similar actions and policies being advanced in the US. Of course, the US and Hong Kong are not alone in experiencing this illiberal authoritarian turn. A closer forensic look is essential.
The crackdown in Hong Kong well illustrates how an established liberal constitutional order in a highly developed open society can be dismantled with alarming rapidity. Hong Kong’s previous liberal constitutional order and its subsequent authoritarian transition checks all the boxes for a useful comparison with current US policies. Are Americans now experiencing a similar transition? If so, how might this perilous path be avoided?
Why Compare Hong Kong?
Under Beijing’s crackdown Hong Kong transitioned from one of the freest rule-of-law-based open societies in the world to a repressive illiberal order. Its core freedoms were effectively undone. As the oldest liberal constitutional democracy in the world, is the US about to suffer the same fate?
Widespread ramifications due to greater US influence clearly distinguishes the likely impact of the US case, but the pieces of this puzzle on the ground are alarmingly similar. At the same time, the passionate resistance we saw in Hong Kong should be an inspiration for US popular defiance. For Hong Kong, the writing was already on the wall under the Sino-British agreement surrendering control of the city to Beijing, a notoriously hardline regime. For the US it need not be.
That Hong Kong’s repression is being orchestrated by America’s chief autocratic rival, China, further makes it a worthy comparison. US foreign policy has long been obsessed with influencing China’s political development and limiting its autocratic influence. There has been much less concern about impacts going the other way. China, unlike the former Soviet Union, has not tried to spread communism around the world.
Viewing the promotion of liberal democratic values as an existential threat, the Chinese Communist Party has instead sought to block the seeds of liberal values being planted at home and promote the development of market-based authoritarian regimes abroad. Authoritarian governments are less likely to challenge China’s human rights record. Hong Kong has recently become the poster child for this design. While Trump’s erratic policies may worry Beijing, a US tilt toward authoritarianism would not.
While not a full-fledged democracy, pre-crackdown Hong Kong was repeatedly ranked at or above the US as one of the most liberal open societies in the world. (Figure 1) In Hong Kong you could freely read, write or spread any information about China, Hong Kong or the world. The city was famous for its independent common law courts, a free and vigorous press, a non-partisan civil service, liberal education, academic freedom, popular protests, and an economy comparable per capita to Western democracies.
Figure 1. V-Dem data (https://v-dem.net/data_analysis/VariableGraph/) shows how closely Hong Kong and the US tracked each other on civil liberties until the 2020 National Security Law was imposed.
Given his trade war with China, it is surprising to find that Trump domestically appears to be playing by China’s authoritarian playbook as now applied in Hong Kong. Wittingly or not, his policies in the US often track Beijing’s illiberal assault on Hong Kong’s freedoms. A city known for its massive public protests and vigorous free press has gone silent. Will the US follow suit? After 250 years of liberal constitutional development Americans might be skeptical. To appreciate the danger, we need to take a closer comparative look at the multiple areas of this dramatic assault on those liberal institutions that check executive power and enable basic freedoms.
The Assault on the Courts
At the leading edge of the Hong Kong crackdown has been Beijing’s skepticism of independent courts as a liberal check on executive authority. Beijing officials have long attacked Hong Kong judges who challenge abuses of power. Such attacks ratcheted up during the 2019 protests and after the 2020 crackdown began in earnest.
Under the 2020 Beijing-imposed National Security Law (NSL) only “designated judges” can hear national security cases, and they face dismissal from such status if they make statements that meet with Beijing’s disapproval on vaguely defined national security grounds. Such disapproval is often signaled by official attacks in the Beijing controlled media. Such Beijing criticisms often notoriously trigger local government officials to appeal unfavorable judicial rulings to higher courts and sometimes to Beijing.
In a similar fashion, the Trump administration has repeatedly attacked US courts working to uphold the rule of law and check executive power. Trump has combined this with persistent efforts to sidestep or ignore judicial orders. Frequent government appeals and attacks have attempted to limit the lower courts’ authority, with such courts accused of usurping the president’s executive power. Court orders to protect immigrants targeted for deportation have often been ignored, as have orders to carry out congressional mandates and appropriations. Government agencies that might get in the way of the MAGA agenda have simply been defunded or ordered closed, often sidestepping judicial orders.
Degraded Civil Liberty Enforcement
The legal assault does not end at the courthouse. The Hong Kong government has largely abandoned civil rights enforcement, as has the Civil Rights Division of the US Department of Justice (DOJ). Both have turned to more ideological approaches. The Hong Kong Justice Department has emphasized a Beijing style national security concept that promotes an illiberal agenda and largely precludes political resistance. This has included prosecutions of just about anyone in politics or the media who dares to speak out against such policies. It has further included warrants and bounties on critical Hong Kong activists overseas.
In a similar ideological vein, the US DOJ now targets what the Civil Rights Division director perceives as anti-conservative bias or “woke” ideology. Like the case under China’s national security regime, under Trump liberal critics have become “the enemy within.” This represents a shift where the chief target of national security is seemingly the American people, very much tracking China’s approach to it own people. Administration complaints about the Biden administration “weaponizing” the DOJ ring hollow in the face of its own full-throttled weaponization. Bill of rights guarantees relating to basic freedoms, discrimination and the rule of law are largely ignored. As a result, about half the lawyers in the US DOJ Civil Rights Division have reportedly quit.
In Hong Kong, a particularly grievous assault on civil liberties has taken shape in the processes of arrests and detentions. The Beijing imposed national security law altered traditional common law principles presuming a right to bail in criminal prosecutions to create a presumption against bail in national security cases. This has allowed those facing national security related charges to be held for three or four-years pending trial. There are even national security provisions that allow removal of prosecutions to the mainland, where most rights are ignored or degraded.
The Trump administration has similarly detained alleged illegal immigrants without any proceedings on their justification for detention. In some cases, these detainees have been shipped off to foreign prisons for what appears likely to be permanent detention without trial. Added to this abuse, there are now reports of the US administration suggesting suspension of the writ of habeas corpus, which would remove the primary common law avenue for an arrestee to challenge his or her detention.
Loyalty and Accountability
Administrative functions and oversight have likewise felt the authoritarian impact. Presumably non-political civil servants in Hong Kong, like federal workers in the US, have faced demands for personal or ideological loyalty to the new regime as a price of continued employment. Such loyalty has become the chief test of administrative accountability. Those who come up short will lose their jobs.
President Trump has repeatedly promised to prosecute his rivals.
Oversight of administrative behavior more generally has also suffered. Hong Kong now has independent national security bodies that are beyond judicial review, as well as special police and prosecutorial entities that operate with total secrecy with little or no accountability.
The massive purge of the civil service in the US has further eliminated or degraded administrative accountability. Many departments charged with oversight have been abolished, while other independent agencies have seen their independence degraded. Even judges being vetted for appointment to the federal bench are being chosen more for their loyalty to the administration’s agenda than to the constitution. Further, previously independent inspector generals have been purged by the so-called Department of Government Efficiency (DOGE), itself an extra-legal organization. The firing and replacement of top military brass has been especially concerning, a non-political military being central to the US liberal constitutional order. The posting of troops on the ground in Los Angeles has highlighted the consequence of this change.
Legislative Oversight Degraded
The legislative bodies of both Hong Kong and the US have been neutered in their oversight roles. Hong Kong had previously developed a slight degree of democracy, with half the members of the Legislative Council directly elected in competitive elections.
This feature had provided some legislative oversight of the Beijing-appointed officials. In 2021 Beijing by fiat abolished even this partial accountability, imposing a “patriots only” electoral system designed through a complex vetting process to exclude opposition candidates from running for office. Nearly the entire political opposition had already been arrested earlier that year and would later be convicted of national security violations for conducting a primary election. In all elections since only so-called “patriots” have been allowed to run for office, barring opposition candidates.
President Trump has repeatedly promised to prosecute his rivals. He has further largely silenced the Republican majority in both the House and Senate by threatening to unseat any party colleagues who speak out against him, effectively neutralizing critical legislative oversight. With a flood of executive orders, he seems intent on ruling by fiat. As a result, the administration has ignored both laws mandating budget allocations and those creating official bodies to carry out established government policies.
While not yet reaching the scale of mass arrests of opposition democrats in Hong Kong, federal agents have arrested several Democratic Party members who have showed up to protest the immigration crackdown. The administration has also sought to burden voting access with strict identification requirements, presumably to manage electoral outcomes going forward. Trump administration officials are of course notorious for claiming, without a shred of evidence, that the 2020 election, conducted while Trump held the presidency, was rigged.
Freedom Undone
In both Hong Kong and the US this affront to liberal constitutional oversight does not end with the assault on the three branches of government. Other checks on official behavior have likewise been degraded. Beijing’s Hong Kong playbook quickly sought to silence critical media, arresting the publisher and shutting down the leading opposition newspaper, the Apple Daily, as well as targeting several prominent online newspapers.
The leading public broadcaster, modeled on the BBC, received new national security guidelines that have stifled its independence. Such intimidation and regulation have been accompanied by other strategies long a part of the Beijing playbook such as preferential selection of reporters invited to government media events and direct attacks on journalist for their reportage.
The Washington examples on the media front similarly include preferential selection to block out leading media organizations, such as wire services, from access to Whitehouse coverage, efforts to defund public broadcasters, and Trump’s frequent targeting of reporters he disfavors, as well as his broadbrush attacks on the mainstream media as fake news.
Critical community organizations have felt the same heat in both places. In Hong Kong such organizations were generally behind the many massive non-violent protests the city experienced over the decades. From 2020, facing arrest or threats of arrest, over sixty Hong Kong pro-democracy or human rights organizations disbanded, as did major labor unions. The legal profession likewise felt this heat, with both the Bar and the Law Society pushed to elect Beijing-friendly leadership.
The Trump administration approach has been to dramatically cut traditional US funding to organizations that research and promote America’s liberal democratic values. Prominent funnels for such funding, such as USAID, the National Endowment for Democracy, the US Peace Institute, and the Wilson Center, among others, have been targeted for defunding, with several effectively being shut down. Only court orders have stood in the way of some of these efforts but again raising question whether such court orders will be ignored or not fully carried out.
This US purge has targeted not only democracy and human rights-focused NGOs, but also those that address scientific research, health and poverty concerns in the US and around the world. Of special concern for the rule of law, has been the revenge targeting of prominent US law firms who have worked for Trump’s opponents or were employed in cases against him. The outcome, as in Hong Kong, is a silencing or degrading of social justice advocacy, as some organizations, bent on survival, surrender to Trump’s improper demands.
Stirring Up Violent Resistance
Perhaps the ugliest part of this authoritarian playbook is when zealous officials weaponize excessive police force to stir up violent resistance and chaos. Such resistance is in turn used to justify further repressive measures. This ugliness has been evident in Hong Kong and the US. In Hong Kong such playbook began with a violent police crackdown on protesters in 2019. Wild scenes of tear gas and police violence brought out more protesters and increased protest violence. Well over 10,000 mostly youthful protesters were taken into custody. In the months and years since, several thousand were prosecuted for various public order offenses and subjected to stiff sentences.
The US administration is following a similar playbook. At this writing such a scene is playing out on the streets of Los Angeles. Protesters had taken to the streets in reaction to the perceived heavy-handedness of US Immigration and Customs Enforcement (ICE) in carrying out Trump’s deportation agenda. Instead of allowing local police to handle this in a measured manner the Trump administration called out the National Guard and even the US Marines over the heads of the state and city governments.
As in Hong Kong these excesses were widely seen as inflammatory efforts to stir up chaos and justify an aggressive crackdown on any public resistance to the administration’s immigration policies nationwide. President Trump had long signaled, in reaction to the “black lives matter” protests during his first administration, a willingness to call out the army to restore order. We can only guess how far he will go in this regard.
Illiberal Education?
The attacks on educational institutions highlight the breath of this authoritarian playbook. In Hong Kong the crackdown targeted the city’s rich tradition of liberal education. New guidelines were imposed on schools at all levels. The old emphasis on liberal and critical education was replaced with an emphasis on patriotism and Beijing’s version of national security. Students were encouraged to report on classmates or teachers who offended such notions. As a former Hong Kong professor, I especially notice that the publicly engaged universities where I worked have largely gone silent in any areas of political sensitivity.
While US democracy currently faces severe challenges, this is not the first, not the last time for such.
In the US, this sort of repression in the education sector has taken its American form in the ideological attacks on DEI, in the withdrawal of billions of dollars in federal research funding, in threats to withdraw universities’ tax-exempt status’ and in the targeting of international students.
Excuses aside, these attacks are essentially because universities, and teachers more generally, are thought to be liberal purveyors of “woke ideology.” The administration has even issued executive orders against Harvard University, initially blocked by a court order, that seek to bar admission of international students.
In the US, foreign citizen students and faculty are being arrested and deported for the sort of speech that has always been protected, such as protesting the war in Gaza. Researchers and professors who disagree also risk losing their jobs or critical funding. The US administration has sought to take over and control what is taught at both the secondary and tertiary levels. One can only wonder how a government in a democratic society, in a country made up largely of several generations of immigrants can be against diversity, equity and inclusion, as these terms are commonly understood, and even bar the discussion of the same.
New Age Authoritarianism
A key characteristic of this new age authoritarian model is that both governments claim to be strictly following their constitutional mandates and international human rights more generally, even while violating both the letter and the spirit of these laws. Rather than the classic jackboots of a military coup, liberal institutions remain in place even while they are severely degraded and captured, ultimately opening the door to unchecked repression.
Ironically, one prominent member of the Trump administration, Secretary of State Marco Rubio, as a senator, was previously involved in hearings and statements condemning similar policies in Hong Kong.
While these examples only scratch the surface, it is important to appreciate that claims of following an authoritarian playbook are more than rhetoric. This playbook involves an assault on a catalogue of specific practices designed to check executive power. While comparing the US with countries with radically different religious, cultural and economic traditions often encounters cultural objections, comparison with a common law jurisdiction deeply steeped in a similar liberal order may better highlight the risks involved.
Before the Beijing crackdown, as one of the world’s leading financial centers, Hong Kong had come to function largely like New York or London, attractive for its strong commitment to the rule of law, basic freedoms and world class liberal education. Its small size and the public’s passionate defense of liberal values, evident in the massive 2019 protest, are quite familiar to Americans, with their long history of similar protests over civil, labor and free speech rights.
Push Back
Sadly, the resistance to Trump’s authoritarian policies has appeared weak or poorly organized. This is not to say there has been no push-back. Erica Chenowith and others have charted a dramatic expansion of the number of protests in Trump 2.0. Polling shows that well over half of Americans strongly oppose Trump’s policies. The nationwide “No Kings” protests well illustrate this resistance. Other resistance has been evident in assorted boycotts (especially the #TeslaTakedown campaign), strikes, disinvestment, court cases, and in voter expression of outrage at townhalls and other gatherings.
The sheer volume of the above noted repressive policies and other unpopular international policies not addressed here, such as tariffs and the wars in Ukraine and the Middle East, have overwhelmed the planning of collective action. Americans have had to be convinced that a fundamental threat to the foundations of democracy can arise in the United States. These are values that many Americans may have thought indestructible after 250 years of development. As this comparison suggest such American traditions are destructible.
Ruled from outside by one of the world’s leading authoritarian powers, Hong Kongers had little chance of stopping the crackdown they faced, though the massive protests of 2019 showed they tried. But the US is in a much better position to resist. The only obstacles are a mix of disbelief, complacency, and the coordination of collective action.
The Art of Resistance
As highlighted in a recent Foreign Affairs article on resistance strategies in other countries (March 2025) by Laura Gamboa, authoritarian drift needs to be nipped in the bud. Early organized resistance on multiple fronts is vital. Hong Kong people in their massive 2019 protests had the right idea but lacked access to the power center a thousand of miles away in Beijing that controlled their fate. Americans do not suffer this limitation.
Some actions already taken have been significant, such as the numerous court cases civil liberties groups and others have filed, though a conservative-dominated US Supreme Court may weaken this course of action. As noted above, boycotts, strikes, disinvestment and other forms of noncooperation can also be helpful. Building a local political base through local elections and townhalls and other forms of community organizing will be crucial. US Congresswoman Alexandria Ocasio-Cortez and Senator Bernie Sanders, on a recent speaking tour, set a good example in this regard.
There is a much greater need for coordination of non-violent collective action to coalesce an informed and shared political agenda. Rights are only as good as their public support and enforcement. Every public channel must be fully used. Activists can combine legal and legislative actions both to protect their advocacy and to advance their cause. Popular protests alone do not guarantee success but can draw attention to the issues.
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Other forms of collective action might include institutional responses by academic and professional organizations. The universities, media and legal organizations now under severe attack need to generate a collective voice both locally and internationally. As Hong Kongers appreciated, international attention can be as important as local attention in drawing support and mobilizing political pressure.
While the US Democratic Party is slightly short of a majority in both houses of Congress it is not powerless. Trump’s use of executive orders has removed much of the debate from Congress, but he will eventually have to do the legislative work if his agenda is to stick. His so-called “one big beautiful” tax bill now in Congress is the first effort in this regard. The Democratic Party will need to be fully present for every vote, to obstruct if necessary, much as the Republicans did for the past two Democratic administrations.
On this score Hong Kong is again an example. Due to a rigged electoral system prior to the crackdown the democrats in the Hong Kong Legislative Council were a permanent minority, holding about one-third of the seats—though typically earning nearly sixty percent of the vote for the half of the body that was directly elected. The legitimacy of their position allowed them to take the high ground on the rule of law and human rights commitments in the Basic Law and the Bill of Rights. By this avenue they were able to shape the public debate and often advance liberal democratic values and related legislation.
In the US, a recent 25-hour Senate filibuster speech by Senator Cory Booker offers an example of an elected legislator prominently taking the high ground. More of this will be required, perhaps a legislative chain of such action.
While US democracy currently faces severe challenges, this is not the first, not the last time for such. Viewed through the critical eye of comparative authoritarian practice there is no longer any doubt as to the reality Americans face. The only question is the actions to take. As with Hong Kong, foreign voices supporting liberal democratic values will also matter.
