Yep and it is propaganda to say there is a restriction on that here. Why do seemingly intelligent people believe this nonsense. I asked
@ChicagoBlue for examples. None forthcoming yet.
Free speech laws in the U.S. and the U.K. differ significantly due to their legal frameworks and historical contexts. Here are the key differences:
1. Constitutional Protection vs. Parliamentary Law
U.S.: Free speech is explicitly protected under the First Amendment of the Constitution, which prevents the government from restricting speech, with limited exceptions (e.g., incitement to violence, defamation, and true threats).
U.K.: There is no single constitutional provision guaranteeing free speech. Instead, it is protected under common law, the Human Rights Act 1998, and European Convention on Human Rights (ECHR) Article 10, but with broader limitations.
2. Hate Speech Laws
U.S.: Hate speech is generally protected unless it incites imminent violence or includes direct threats.
U.K.: Hate speech is criminalized under laws like the Public Order Act 1986 and the Communications Act 2003, making it illegal to stir up racial, religious, or homophobic hatred.
3. Defamation Laws
U.S.: Plaintiffs in defamation cases, especially public figures, must prove actual malice (knowledge of falsehood or reckless disregard for the truth), making lawsuits harder to win.
U.K.: Defamation laws are stricter, and the burden is on the defendant to prove the truth of a statement. The Defamation Act 2013 introduced reforms, but it is still easier to sue for libel in the U.K. than in the U.S.
4. Online Speech and Social Media Regulations
U.S.: Platforms are generally shielded from liability for user-generated content under Section 230 of the Communications Decency Act, though there are debates over reform.
U.K.: The Online Safety Act 2023 introduces stricter regulation on tech companies, requiring them to remove harmful content, including legal but "harmful" speech.
5. Protests and Public Order
U.S.: The right to peaceful assembly is strongly protected, though local governments can impose reasonable time, place, and manner restrictions.
U.K.: The Public Order Act 1986 and Police, Crime, Sentencing and Courts Act 2022 allow authorities to restrict protests based on noise, disruption, or risk of disorder, giving police broader powers than in the U.S.
6. Blasphemy and Religious Speech
U.S.: Blasphemy laws do not exist, and religious criticism is fully protected.
U.K.: The last blasphemy laws were abolished in 2008, but laws against religious hatred (e.g., Racial and Religious Hatred Act 2006) can still limit certain types of speech.
Conclusion
The U.S. has broader free speech protections due to the First Amendment, while the U.K. places greater emphasis on balancing speech with protections against harm (e.g., hate speech and defamation laws). This makes speech in the U.K. more regulated, particularly in online spaces and public protests.