Similar Interpretations, Different Conclusions: The Criminalization of Hate Speech in the West
McCann, Wesley S.
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The United States is unique internationally in that hate speech is not considered a criminal offense. Drawing from a sample of Western countries and their respective statutes, the analysis will look at different nations’ interpretations of hate speech criminality. This study identifies common patterns in international criminal legal codes and compares them to U.S. jurisprudence, focusing on content neutrality and the ideological content of these laws. It was found that hate speech statutes internationally tended towards content neutrality, were structured similarly to anti-defamatory codes, and generally did not result in amendments/extensions of new regulatory laws. These findings imply a closer relationship between the logic of hate speech criminality to U.S. jurisprudence than otherwise assumed.