Political philosophers have considered a number of different theories attempting to ground 'political obligation', that is, the obligation to comply with the state or government. One that, since the 1970s, has usually been quickly dismissed is the gratitude theory of politial obligation. This theory says that people have an obligation to support the state due to having received benefits from the state. It seems to be a quite general consensus that it is untenable. However, when one looks at the arguments that have been used against it, they consistnetly use implausible and, indeed, sometimes obviously incorrect accounts of gratitude. It is true that gratitude cannot be a complete theory of political obligation, but that is something that it shares with any single-factor theory; 'political obligation' is not a single thing, and therefore has no single account. But the gratitude theory, despite being incomplete, is correct insofar as it identifies a kind of political obligation that is genuinely important, and all of the arguments that are typically used against gratitude being a ground of political obligation are astoundingly bad.
It is worth making one especially important precisifying point. The gratitude theory says that the obligation to support the state arises form having received benefits from the state. It follows from this that, despite the name, the gratitude theory does not only involve gratitude. There are other moral qualities that are concerned with reception of benefits. Some of these deal with very specific kinds of benefactors -- e.g., filial piety with parents and religious virtue with God -- and others with specific kinds of benefits -- e.g., there are kinds of respect specifically concerned with eminence or excellence. These may sometimes be relevant, but are not going to be universal. However, besides gratitude there are two other kinds of virtue associated with response to benefits, and, what is more, gratitude in some sense presupposes them both -- that is, they have a sort of priority over gratitude in that gratitude specifically deals with benefits insofar as they are not covered by them. These are observance, which is respect for governance itself specifically insofar as its eminence contributes beneficially to one's life (e.g., by providing a dignity with which we can be associated or by setting things in a useful order), and justice, which gives a return so that things are even/level/fair. Fairness is often contrasted with gratitude, and it is true that they cover different ground, but a gratitude theory, to make sense of gratitude's role specifically, has to make room for other benefit-responses, because it often presupposes them. For instance, if I receive benefits from a contract, I must in justice fulfill the contract fairly, not taking advantage, but beyond that, I may also have to give something in gratitude -- e.g., if the other party to the contract fulfilled their part excellently, or in an especially helpful way, or by going above and beyond what would normally be expected. This sort of gratitude is distinct from, but certainly not separate from, justice or fairness, and the gratitude is specifically concerned with the obligations of the latter.
Therefore, contrary to the way it is sometimes discussed, the gratitude theory has to be understood as saying that the our political obligation arises at least from gratitude, not that it arises only from gratitude; or, perhaps more narrowly but accurately, that it arises in complete form with gratitude, but not that gratitude is the only thing that contributes to it. This is in fact clear from discussions; when people attempt to explain the content and implications of the gratitude theory, they clearly say things that apply to observance or justice, not just gratitude. However, when people criticize the gratitude theory, they regularly criticize it as if it only involved gratitude, and base their criticism entirely on purported features of gratitude without even looking at whether observance or justice might contribute something.
When A. J. Simmons argued against the gratitude theory in the late 1970s, he did so by arguing that obligations associated with gratitude had certain features that were problematic with respect to establishing an adequate ground for political obligation, which we might briefly summarize as:
(1) Obligations of gratitude are only for special benefits, i.e., benefits that required special effort or some kind of sacrifice.
(2) Obligations of gratitude only arise when the giving of the benefit is not unintentional, involuntary, or for a disqualifying agenda.
(3) Obligations of gratitude only arise when the beneficiary wants and accepts the benefit as being from the benefactor, or at least would want and accept it as being from the benefactor if certain conditions were met.
Most arguments against the gratitude theory since Simmons have been based on some version of these. Unfortunately, each of these three is simply incorrect. We can (and very often do) have obligations of gratitude for ordinary benefits that involve no special effort or sacrifice, obligations of gratitude for benefits given defectively, and obligations of gratitude toward people or for things we did not particularly want. What does change in these cases is how one fulfills the obligation. But anyone who acted according to the three principles above would often be an ingrate.
A simple way to recognize that (1) is false is to look at cross-cultural practices of gratitude, which regularly involve various kinds of thanks and/or return for entirely ordinary things like passing the salt. Yes, these are often perfunctory, but they are responses to things that are themselves usually perfunctory, and at least the consistent failure to say "Thank you" for small favors (if saying "Thank you" is the cultural custom for grateful actions) is a sign of someone lacking in gratitude. Any particular small favor, of course, might not be much in the way of a benefit, but it is often at least a little beneficial, and many of these tiny benefits can make a significant difference to one's life. Gratitude has to enter in somewhere, and perhaps we could sometimes make it a package deal -- instead of expressing gratitude for each and every bit, we might express gratitude all at once for the whole lot. But given the wide variety of situations under which these benefits are given, we are often not going to be in a position to know that we could later give thanks, and therefore people will often show gratitude bit by bit, in case they can't later. We are in fact obligated to be grateful for all benefits whatsoever, and to express this when it is appropriate, and there is a way to do so, and we are able to do so, in a way that is appropriate for that kind of benefit.
(2) is on much stronger ground, because there quite clearly are disqualifying grounds for gratitude. For instance, if someone gives an apparently good gift but, as it turns out, with the intention of actually harming you or someone else, this is obviously not something that calls for gratitude, because this is only apparently a benefit. Likewise, if someone seems to benefit you but, it turns out, is taking credit for something that is really due to them, they are not (at least thus far) due any gratitude because they are only apparently a benefactor. Both of these, however, are cases where there is only an appearance of what gratitude requires. It's less clear whether lack of intention and lack of voluntariness disqualify. It's clear that the response of gratitude may still be required in unintentional or involuntary cases -- we know this because we can be grateful toward nonrational things that happen to benefit us, and this is in fact a common human response -- but many of thems will not call for an obligation of gratitude. The key issue, however, would be whether there is a real moral debt to a person for a real benefit really given. If these three features are in place (moral debt, benefit, act of giving), then it seems that we have a genuine obligation of gratitude. Lack of intention or lack of voluntariness would seem to have to actually eliminate one of these three in order to prevent an obligation of gratitude. But in practice, we will not always be in a position to assess whether a benefit is given wholly involuntarily or unintentionally, and therefore we can have an 'overflow obligation' of gratitude -- that is, we can be obligated because as far as we know there may have been at least some aspect of the beneficent action that was intentional or voluntary enough. One of the marks of an ingrate is someone who refuses to act with gratitude toward something unless it can first be proven that it was done in the right spirit and way. Such an attitude would inevitably result in genuine benefits being received without gratitude simply on the basis that they can't meet the arbitrarily high standard we have imposed for being grateful.
(3) is obviously not going to work, because it would mean that, across a vast range of cases, whether or not you should be grateful would depend entirely on whether you feel like being so. Most benefits for which we are grateful are given without anyone first getting our clear consent to be benefited. There are of course times when we are 'benefited' exasperatingly with benefits we don't want because they are actually useless or harmful, and this circumstance would clearly affect the manner in which we need to respond. But we have obligations of gratitude not merely for the gift but also for the giving, and while it is difficult to be grateful to someone who is 'helping' in unhelpful ways, if they are genuinely sincere, we will at least often have the obligation to be grateful for the generosity of their heart, God bless 'em.
Given all of this, we can actually have obligations of gratitude under an extremely wide range of conditions, and there is no reason to think that we cannot thereby have obligations of gratitude to the state or government, given that we almost certainly receive particular benefits from them -- roads and schools and national defense and so forth. Socrates in the Crito was right, at least thus far: acting ungratefully to the city whose laws raised and nurtured and protected you is a genuine form of ingratitude, and you can be obligated to the city for the benefit of its laws.
Beyond trying to argue against the gratitude theory of politial obligation on the basis of a flawed notion of gratitude, there are two other more promising arguments that often are made against it. First, obligations of gratitude do not give sufficiently forceful obligations. Second, obligations of gratitude do not give sufficiently specific obligations. While better, these are also flawed.
The essential idea of the first argument is that the state has the right to demand compliance and punish refusal to comply, whereas it seems that obligations of gratitude do not allow for this kind of demand and punishment. The point about demand can, I think, be questioned -- if someone is ungrateful, it does sometimes seem appropriate to demand that they show a little gratitude. But it does seem that the circumstances under which you could punish someone for being ungrateful to you, beyond simply cutting them off and refusing to keep benefiting them, are pretty limited. Nonethless, I think there are two things to be said to this. First, we should push back hard, I think, on any claim that the state has a general right to demand and punish. This seems widely to be assumed, but this is because much modern political philosophy is effectively totalitarian, taking the state to have universal power and authority rather than, as is the more correct and certainly the politically and morally safer position, taking it to be quite limited in power and authority. When you stop making that assumption, it does seem that the state needs to earn its right to demand and punish by something like clear and manifest benefits. The state does not exist for itself; it exists to serve. If it is doing so badly, it is unclear why we should think that that has no effect on its right to demand and punish. Second, as noted above, gratitude sometimes presupposes justice, and most of the obvious cases of the state have a definite right to demand and punish seem clearly to be cases in which justice is the key factor, rather than gratitude as such (which may, however, affect how we should comply). What the argument gets right is that some political obligation is what used to be called a 'legal debt' or 'strict debt', whereas gratitude gets us only what used to be called 'moral debt' or 'customary debt'. Justice, however, gets us to legal debt, so some gratitude can incorporate the legal debt of justice as part of what one considers in satisfying the moral debt of gratitude.
The second argument seems to be the one that political philosophers have found most conclusive, and is the one most often found. The basic idea is that whereas political obligation seems often to require very specific things -- paying taxes, obeying this or that law, complying with the draft -- obligations of gratitude don't seem to be specific in this way. This is true, but this is because the bare fact of being grateful is itself not a specific thing. The grateful response, however, has to be responsive to particular facts about the benefit received and how it is given, and this means that the response of the grateful person is always quite specific and adapted to the situation. One of the things that is always considered is what means are available for grateful response, and in fact the ways in which you can genuinely express gratitude to the state for benefits received is quite limited -- states may seem complex, but they effectively need funding, compliance with just law, and noninterference with their legitimate functions, as well as sometimes some symbolic support, which can facilitate their work. Perhaps there are other things, but there's not much else that most people most of the time could do in order to show their gratitude for the benefits of the state. States are quite simple, really; they require remarkably little, so there are usually only a limited number of ways you can respond gratefully.
Again, none of this is to say that the gratitude theory can be a complete theory of political obligation -- political obligation is so complicated that it pretty much guarantees that only a pluralist theory would be adequate. But the point, I think, is clear enough: gratitude can (and, I think, clearly does) play a role in grounding political obligations, and almost all of the arguments against its doing so are defective.