Abstract This article examines the differences in pre-1914 France and the United States in two kinds of state policies regulating women's behaviour, those “protecting” the condition under which women participated in certain occupations and those providing infant and maternal protection. Those policies are examined to illuminate the argument that politics, including state policies, makes an important contribution to the maintenance and change of ongoing systems of social relations. Central to this argument is the notion that meaning systems around which actors constitute collective identities are a crucial analytic focus for understanding stability and change. At the end of the nineteenth century hegemonic societal paradigms, constructed out of the processes institutionalizing new social relations, emerged in France and the US. The French paradigm of “citizen-producer” and the American one of “specialized citizenship” had quite different implications for the patterns of gender relations embedded within them. These implications are visible in the treatment of women's work and maternity in these years of the emerging welfare state.
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