The UK (and Europe's) free speech problem

In any case, defamation isn’t protected speech.

Eh, in practice what matters is who you are and who your target is; the right wing is rabidly defamatory all the time and never punished for it. Privilege matters, not law.

Absolutely, I am just saying about in principle.
Because it seems to be a common misconception that free speech means the right to say any words in any situation. That’s not true in America, or anywhere else, and never has been. It’s always been more nuanced than that.

But agree with you that today defamation is much more about who has money and power. Same with IP law…ETA: off-topic rant deleted

Owens is in no way a journalist, at best she’s a polemicist.

So how does an American libel case (showing as it does that that, just like in Europe libel is not protected speech in the US) have any baring on the UK criminalizing speech that “causes alarm”?

And Trump would never do anything blatantly hypocritical :roll_eyes:

Again, if that’s the case why hasn’t Trump started prosecuting people for saying mean things about him? He clearly wants to, and has said as much.

American democracy is hanging on by its fingernails and several of those fingernails are the bill of rights

He’s sued multiple media organizations and pressured them into e.g. firing Colbert. Now, obviously I said upthread that defamation is not protected speech. But while Trump is still president it’s obvious that he can put undue pressure on organizations to fold – which lawyer anywhere has said that Trump had a winning case against CBS for its edits to the Kamala interview? Yet they settled.

Additionally Trump has pulled funding from universities and other organizations on the basis of their speech (e.g. palestine, climate change, trans), or even the protests that they allow, and blocked entry to white house briefings from agencies that don’t toe the line.

This is just off the top of my head. The first amendment is looking hella weak right now.

Except that it really is different, and it’s not about some kind of “exceptionalism” – America is the only country on earth that has ever declared itself “exceptional”.

There is a different social culture here, a strong sense of liberal democracy, with a strong consensus of support for universal health care and for a national public broadcaster promoting a more informed public. Canada was one of the first countries in the world to recognize same-sex marriage, and while the US faces the fallout of overturning of Roe v Wade, abortion has been completely legal here for many decades. And the Westminster parliamentary system of government is much more accountable than the American presidential system.

No, I don’t think hate speech laws are going to be creating tyranny here any time soon. Within reason, balancing a constitutional guarantee of free speech with sensible, limited hate speech laws poses no risk to anyone except those who are harmful to a peaceful social order.

I’m pretty sure lots and lots of countries have done that.

“American exceptionalism” specifically means, in practice, that they don’t give a shit about how things are done in other countries because it’s irrelevant in America, because it’s exceptional and unique. It means that there are no lessons to be learned from other countries’ political systems or social values. I can’t count how often I keep hearing this refrain – and this is not to be confused with citizens simply liking where they live. I know of no other country like this, at least not one that is a putative democracy. Do you?

William Shakespeare would disagree

Chinese exceptionalism has been going on for some 3,000 years. They literally call themselves the middle of the universe or something like that.

~Max

I don’t think so. He’s saying, in very flowery language, “I like England”. Love of one’s country is a very common sentiment, but “American exceptionalism” means something different and specific. As I said before, the concept of American exceptionalism is specifically used – usually by conservatives – to dismiss arguments about superior outcomes from the sociopolitical systems in other countries, and what can be learned from them.

Yes, I can think of plenty of countries where particularly patriotic individuals might say something along the lines of, “Yes, that’s how it happened in XXXX, but WE are YYYYians, so we are different!”.

I gotta say, the claim that American Exceptionalism is Exceptional is quite an amusing one :slight_smile:

But how many countries make such statements when it comes to freedom of speech?

~Max

Only if you confuse it with generic patriotism, as opposed to intransigent closed-mindedness about the rest of the world, which is deemed, as an axiomatic fact, to be inferior in every respect..

No, I get that; it’s just very silly to think that only Americans ever think that way.

I have no doubt that some citizens, in some countries, may think that way. But the point about “American exceptionalism” is that it’s a dogmatic belief deeply entrenched in (mostly) conservative American culture. It’s constantly used as a rebuttal against things that other countries are doing better, like universal health care, gun control, and, yes, laws against hate speech in the furtherance of a more peaceful society.

So you just described your argument exactly. I gave a rational argument as to why the way another country does it is objectively better, with examples. You rebutted by saying the way Canada does it is exceptional and better than the way foreigners do it.

How could I possibly say that when the way that Canada handles hate speech is essentially the same as expressed in the policy framework of the EU and the policies of many other nations. It’s American absolutism about free speech that is unique.