Hate Speech, Democratic Legitimacy and the Age of Trump

Abstract

Should democracies punish hate speech? Eric Heinze, Professor of Law and Humanities at Queen Mary, University of London, has written an important new book on this subject, Hate Speech and Democratic Citizenship. At the center of Heinze’s book is a revolutionary idea: Instead of debating whether democracies per se can or cannot legitimately ban hate speech (which assumes all democracies are the same), we should only condemn hate speech as illegitimate in those democracies that are longstanding, stable and prosperous. In this essay, I show how Heinze’s idea frees the debate over hate speech regulation from the Europe vs. America dichotomy that has haunted it for years, while carrying a special poignancy for the United States in the age of Trump.

Full text

H S, D L
  A  T
(reviewing Eric Heinze. Hate Speech and Democratic Citizenship.
Oxford: Oxford University Press, 2016)
Review by
Rob Kahn1
St. omas University, USA
rakahn@stthomas.edu
KAHN, Rob. Hate Speech, Democratic Legitimacy and the Age of Trump (revie-
wing Eric Heinze. Hate Speech and Democratic Citizenship. Oxford: Oxford Uni-
versity Press, 2016). International and Comparative Law Review, 2017, vol. 17,
no. 1, pp. 239–253. DOI 10.2478/iclr-2018-0011.
Summary: Should democracies punish hate speech? Eric Heinze, Professor of Law and
Humanities at Queen Mary, University of London, has written an important new book
on this subject, Hate Speech and Democratic Citizenship. At the center of Heinze’s book
is a revolutionary idea: Instead of debating whether democracies per se can or cannot
legitimately ban hate speech (which assumes all democracies are the same), we should
only condemn hate speech as illegitimate in those democracies that are longstanding,
stable and prosperous. In this essay, I show how Heinze’s idea frees the debate over hate
speech regulation from the Europe vs. America dichotomy that has haunted it for years,
while carrying a special poignancy for the United States in the age of Trump.
Keywords: Eric Heinze, Hate Speech, Democracy, Legitimacy, Trump
1 Introduction
Should democracies punish hate speech? If Francis Fukuyama was correct
when he said, in his famous essay e End of History, that the “end point” of
human evolution was “the universalization of Western liberal democracy,”2 then
one might expect democratic states around the globe would reach consensus on
this question. Yet they do not agree; rather, there is a split between the United
States, which does not allow bans on hate speech, and most other democracies,
which allow such bans.3 For the past 30 years, scholars from the United States
1 Professor of Law, St. omas University. BA Columbia University (1985), JD New York
University School of Law (1989) Ph.D. Johns Hopkins University (Political Science 2000). I
would like to thank Jacqueline Baronian, Mitchell Gordon, and Eric Heinze for their com-
ments on this article.
2 Fukuyama, Francis. e End of History, e National Interest, 1989, no. 16, p. 4.
3 e divergence between American and European approaches to hate speech regulation
is traced back to the 1950s and 60s when, in response to the Civil Rights movement, the
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and Europe have struggled to account for this lack of a common “end point.”
In general, the arguments have taken two forms: either one explains the diver-
gence by specic cultural tendencies in the countries involved (the exceptional-
ism argument); or one adopts a universal answer to the question of hate speech
regulation, and then fault those societies that fail to follow that standard.4
Neither approach is satisfying. Exceptionalism runs into questions about cau-
sation – what does it mean to say the United States tolerates hate speech because
of its political culture? How do we distinguish causation from correlation? What
if there are multiple causes, how do we single out one as more important than
another? Universalist or convergence approaches to the question, meanwhile,
tend to generate endless debates because hate speech regulation becomes a ques-
tion of principle. If democracies must converge upon a shared norm, the world
becomes a dull, uniform place, in which dierence is by denition heretical.5
In the process, supporters of globalizing, convergence approaches fail to ask a
key question: Are all democracies equally justied in tolerating or banning hate
speech?
Wandering into this debate, Eric Heinze, Professor of Law and Humani-
ties at Queen Mary, University of London, has written an important new book,
Hate Speech and Democratic Citizenship.6 Heinze’s book oers a path-breaking
advance over the tired debate between exceptionalism and convergence. At the
center of Heinze’s book is a revolutionary idea: Instead of debating whether
democracies per se can or cannot legitimately ban hate speech (which assumes
all democracies are the same), we should only condemn hate speech as illegiti-
mate in those democracies that are longstanding, stable and prosperous.7 Not
only does this idea free the debate over hate speech regulation from the Europe
vs. America dichotomy that has haunted it for years, it carries special poignancy
for the United States in the age of Trump.
US struck o on a more libertarian approach to speech regulation, including hate speech.
See Walker, Samuel. Hate Speech: e History of an American Controversy. University of
Nebraska Press, 1994, pp. 106–33. However, one can nd Euro-American dierences dat-
ing back to the 1930s and 40s. See KAHN, Robert. Why Do Europeans Ban Hate Speech?
A Debate Between Karl Loewenstein and Robert Post, Hofstra Law Review, 2013, vol. 41, p.
566 (describing how sociologist David Riesman, writing in the 1940s, sought to explain US
resistance to speech regulation as a function of America’s “capitalistic” tradition).
4 For an extended discussion of exceptionalism and universal/convergence based theories of
hate speech regulation, see KAHN, Why Do Europeans Ban Hate Speech?, pp. 547–51.
5 For an extended critique of convergence approaches to hate speech regulation, see KAHN,
Robert. Flemming Rose’s Rejection of the American Free Speech Canon and the Poverty of
Comparative Constitutional eory, Brooklyn Journal of International Law, 2014, vol. 39,
pp. 692–94.
6 Heinze, Eric, Hate Speech and Democratic Citizenship. Oxford: Oxford University Press,
2016.
7 Ibid, pp. 69–78.
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2 Determinism and the Debate over Hate Speech Regulation
For Heinze, the global debate over hate speech regulation is too determinis-
tic.8 If hate speech regulation is the norm in Europe but not in the United States,
the reason must rest on cultural or historical reasons that determine how a coun-
try responds to this question. erefore, if the United States has largely toler-
ated hate speech since the 1960s, this is because of deep-rooted causes that go
back to the founding of the country and are, for that very reason, unchangeable.
e same applies to Europe: If Germany, France or Austria ban hate speech (or
Holocaust denial) this is rooted in factors – such as the Nazi past – that an out-
sider could not possibly understand, let alone try to change.9 As early as 2009,
Heinze understood the problem when he described academic conferences on
hate speech regulation as meetings taking place between American “wild west
cowboys” and European “cheese eating surrender monkeys” who talk past each
other.10 In 2016 he adds that these “implausibly essentialist”11 descriptions of
Europe and America, even if correct in part,12 push the discussion about hate
speech regulation into a “determinist dichotomy between semi-civilized Ameri-
cans revering aggressive individualism above all other values versus lethargically
timorous Europeans yoked to government-dictated notions of the collective
good.”13
To be sure, Heinze is not the only one struggling to break free of the conn-
ing grasp of the Euro-American dichotomy. On the one hand, Yale University
Law School Dean Robert Post has argued that hate speech bans have no place in
any democracy.14 A country that regulates hate speech is simply not democratic;
on this view, Germany and France are – in theory, at least – no dierent from
North Korea.15 e reason for this rests on the nature of democratic legitimacy:
8 Heinze, Hate Speech and Democratic Citizenship, pp. 181–94.
9 For example, Deborah Lipstadt, while opposing speech restrictions on Holocaust denial
more generally, expressed some sympathy for countries that, because of their experi-
ences with the Holocaust, enact such laws. See Kahn, Robert. Holocaust Denial and Hate
Speech. In Hennebel Ludovic, Hochmann, omas (eds). Denials and the Law. Oxford:
Oxford University Press, 2011, pp. 93–94 (describing Lipstadt’s views). For his part, Heinze
observes that, given the Nazi predilection for book burning, the Nazi experience could just
as easily counsel speech protection. Heinze, Hate Speech and Democratic Citizenship, p. 64.
10 Heinze, Eric. Wild-West Cowboys versus Cheese-Eating Surrender Monkeys: Some Prob-
lems in Comparative Approaches to Hate Speech. In Hare, Ivan, Weinstein, James (eds).
Extreme Speech and Democracy. Oxford: Oxford University Press, 2009, p. 182.
11 Heinze, Hate Speech and Democratic Citizenship, p. 181.
12 Heinze concedes that “Europe and the US take currently take opposite approaches to view-
point-punitive bans within public discourse.” Ibid. at 183.
13 Ibid, p. 187.
14 See, e.g., Post, Robert. Religion and Freedom of Speech, Portraits of Muhammad. Constel-
lations, 2007, Vol. 14 (arguing that Denmark’s anti-blasphemy bans were illegitimate for a
democracy to enact).
15 Ibid., p. 74. For a critique, see Kahn, Why Do Europeans Ban Hate Speech?, pp. 576–81.
To be fair, Post takes a more contextually sensitive approach in his interview with Peter
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Imposing a democratic outcome on a citizen can only be legitimate if the he or
she has had a chance to express his or her opinion.16
On the other side, Jeremy Waldron, in his 2012 book, e Harm in Hate
Speech makes a dignitary-based case justication of hate speech bans, one that
like its democratic counterpart applies in all times and places.17 is formula-
tion leaves the United States a global scoaw that, unlike smaller countries (such
as Canada), has the luxury of ignoring international agreements.18 At the same
time, this type of argument leads back to the exceptionalism parlor game: Why is
the US dierent? Is this due to a wilderness psychology of frontier settlements in
the American West,19 or the way in which the “melting pot” model of assimila-
tion forged US citizens who were oblivious to the ethnic insults that are a staple
of hate speech 20 Or are other factors in play?21
Worse still, the dueling proponents of convergence, like their exceptionalism-
based predecessors, still talk past each other. is comes from a tendency – on
both sides – to fetishize the American experience of free speech “absolutism.”22
If the United States, the paradigmatic liberal democracy, gets along without
hate speech bans, perhaps Europe should as well. Alternatively, the failure of
the United States to punish hate speech is just another drop in the bucket for a
country known, as Heinze himself points out, for its police brutality, death pen-
alty, and large prison population.23 In this regard, the United States is that poor
Molnar. See Interview with Robert Post. In Herz, Michael, Molnar, Peter (eds). Rethinking
the Content and Context of Hate Speech: Regulation and Responses, New York: Cambridge
University Press, 2012, p. 23 (expressing a desire to be “cosmopolitan” in assessing hate
speech policies across the globe).
16 Post, Robert. Racist Speech, Democracy and the First Amendment. William and Mary Law
Review, 1991, Vol. 32.
17 Waldron, Jeremy. e Harm in Hate Speech. Cambridge, MA: Harvard University Press,
2012. While Waldron opens his book with the hypothetical example of a Muslim family
encountering hate speech during a walk in New Jersey, and more generally can be seen as
writing for a US audience, ibid., pp. 1–6, the arguments in his book are not limited to the
United States – or any other democratic society.
18 See Kahn, Robert. Hate Speech and National Identity: e Case of the United States and
Canada, U. of St. omas Legal Studies Research Paper, No. 8–02 (posted: March 10, 2008).
[online]. Available at, <https://papers.ssrn.com/sol3/papers.cfm?abstract_id=1104478>,
Accessed: 22.06.2017, pp. 20–21 (describing the argument of Canadian scholars that the
United States tolerates hate speech because it, unlike Canada, has the power to ignore
international treaties).
19 Ibid., pp. 18–20.
20 Ibid., pp. 5–8.
21 Canadian scholars also attribute the lack of hate speech laws in the US to its problems with
race relations. Ibid., pp. 8–18.
22 See, e.g., Abrams, Floyd. On American Hate Speech Law. In Herz, Michael, Molnar, Peter
(eds.) Rethinking the Content and Context of Hate Speech: Regulation and Responses, New
York: Cambridge University Press, 2012, p. 126 (concluding that the American model of
free expression “may not be for all nations” but it has “served the United States well”).
23 Heinze, Hate Speech and Democratic Citizenship, p. 13.
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performing schoolchild who is damned by George W. Bush’s “so bigotry of low
expectations.”24 Absolutism isn’t a model to emulate, it’s a sign of a problem – a
serious one.25
3 Long-Standing, Stable, Prosperous Democracies
Against this backdrop, Heinze’s Hate Speech and Democratic Citizenship is a
much-needed breath of fresh air. Instead coming to praise (or bury) the United
States as a global democracy, he places the question of when democracies can
punish hate speech in a broader, global context.26 In place of the First Amend-
ment, Heinze discusses the First World (and the Second and ird Worlds as
well). In place of the American wilderness,27 the racist melting pot,28 or Ameri-
ca’s supposed lack of an aristocratic culture,29 Heinze poses a question that can
be answered in Israel, Ireland and India: Does a society have the resources to
protect vulnerable minorities from the harm posed by hate speech?30 In a way,
Heinze echoes Brandeis in his Whitney v. California concurrence,31 who famous-
ly stated: “If there be time to expose through discussion the falsehood and falla-
cies, to avert the evil by the processes of education, the remedy to be applied is
more speech, not enforced silence.”32 For Heinze, the key variable is not time but
social capital. In other words, does a democracy “maintain sucient legal, insti-
tutional, educational, and material resources to admit all viewpoints into public
24 Bush made the speech during his visit to the NAACP national convention in 2000. For a
transcript, see Text: George W. Bush’s Speech to the NAACP, Washington Post, 10 July 2000.
[online] <http://www.washingtonpost.com/wp-srv/onpolitics/elections/bushtext071000.
htm>. Accessed: 22.06.2017.
25 See, e.g., Hutchinson, Allan, C. Waiting for Coraf: A Critique of Law and Rights, Toronto:
University of Toronto Press, 1995, p. xii ( “[D]espite its claim to be a standard bearer of
rights, the record of the United States on issues of race and violence is less than exemplary;
it remains one of the most divisive and troubled countries in the world.”)
26 For example, in his introduction Heinze expresses his desire to overcome the assumptions
that the debate over hate speech bans involves “a stando between ‘America’ and ‘Euro-
pean’ approaches” to the issue and that the allowing hate speech is “suited only to US law
and culture.” Heinze, Hate Speech, supra note 5, at 6–7. To the contrary, Heine observes
that, because of their democratic solidity, “Northern European social-welfarist democra-
cies will prove to be the best situated to abolish hate speech bans.” Ibid., p. 7.
27 Kahn, Hate Speech and National Identity.
28 Ibid., pp. 5–18.
29 See Heinze, Hate Speech and Democratic Citizenship, pp. 12–13 (rejecting the argument
that the US tolerates hate speech because of its more democratic, anti-aristocratic nature).
As Heinze points out, the aristocratic vs. democratic distinction is overstated in part
because for a long time the US had its own aristocracy. See BALTZELL, E. Digby. e Prot-
estant Establishment: Aristocracy and Caste in America. New York: Random House, 1964
(describing the rise and fall of the White Anglo Saxon Protestant elite in the United States).
One view of the Trump presidency is that it seeks to reestablish the WASP elite.
30 Heinze, Hate Speech and Democratic Citizenship, p. 70.
31 Whitney v. California, 274 U.S. 357, 372 (1924) (Brandeis, J., concurring).
32 Ibid., p. 377.
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discourse, yet remain adequately equipped to protect vulnerable groups from
violence or discrimination”? If the answer is “yes,” then viewpoint-punitive bans
of hate speech in that country violate norms of democratic legitimacy.33
Were this all Heinze did, his book would be a great advance on the current
US-centered state of the literature; but he goes a step further by operationalizing
his argument. A democracy should have the resources to combat the discrimina-
tory eects of hate speech if it is longstanding, stable and prosperous.34 By long-
standing, Heinze refers to an unspecied period of time “during which the norms,
practices and expectations of democratic citizenship penetrate a substantial por-
tion of the population.”35 To reach this condition, a state must “maintain, through
anti-discrimination regimes, enforceable policies of civic and social pluralism;
being “value neutral” on these questions will not cut it.36 A stable democracy is
one that can “police itself, according to independently (e.g. judicially) reviewable
criteria.”37 Finally, a prosperous democracy is one that is “suciently wealthy”
that “controversial political or cultural events can proceed, with speakers, audi-
ences, and dissenters alike protected from violence.”38
ese terms, moreover, are capable of quantication; using international
measurements such as the Democracy Index Report published by the Economist,
one can distinguish states that are rst-order democracies from those strug-
gling to become genuinely democratic.39 is allows for the argument that an
advanced democracy (such as the United States) might be able to tolerate speech
that would pose problems for less well-entrenched democracies (such as Israel
and India).40 Heinze also allows the possibility that what he calls LSPD’s (long-
33 Heinze, Hate Speech and Democratic Citizenship, p. 77. Another noteworthy feature of
Henize’s book is how he anchors legitimacy not on a liberal notion of rights, but in democ-
racy. Ibid., p. 9 (distinguishing between “a liberal or human right of expression and a dem-
ocratic citizen prerogative of expression”)(emphasis in original). On one level, therefore, an
LSPD is free to enact hate speech bans, or other speech restrictions. e consequence of
this, however, is that the “state stops being an LSPD.” Ibid., p.72.
34 Ibid., p. 77 (“A longstanding, stable, and prosperous democracy can be fully held to its legiti-
mating expressive condition, which requires the citizen’s prerogative of non-viewpoint-puni-
tive expression within public discourse”)(emphasis in original).
35 Ibid., p. 73.
36 Ibid. is carries a special relevance in the US given the growing critique of colorblindness.
See Alexander, Michelle. e New Jim Crow: Mass Incarceration in the Age of Colorblind-
ness. New York: e New Press, 2010, pp. 240–41 (distinguishing between Martin Luther
King Jr’s dream of being “able to see beyond race to connect spiritually across racial lines”
from taking the position “that one does not care about race” at all). To the extent the US
is “colorblind” – i.e., value neutral – it has not reached a place where the most vulnerable
groups in society are genuinely protected from discrimination.
37 Heinze, Hate Speech and Democratic Citizenship, p. 73.
38 Ibid.
39 Ibid., pp. 69–70 (describing the indicators used in the report and listing those countries
that are highly ranked).
40 Ibid., p. 79, n.35
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standing, prosperous, stable democracies) may have moments of backsliding –
such as the time of troubles in northern Ireland – which might justify the use of
hate speech bans on security grounds.41
In this respect, Heinze builds on Robert Post’s insight that hate speech reg-
ulations that intrude on the public discourse have no place in a democracy,42
while unraveling the American exceptionalism puzzle that has so bedeviled
Post. While Post deserves great credit for his public discourse theory – one that
opens the door to the regulation of hate speech in private realms such as employ-
ment and educational settings,43 an area of convergence between European and
American approaches to hate speech law,44 his rationale for his theory rests on
the specically US experience with the First Amendment.45 Given this, can
Post’s theory have a genuinely global reach, especially in a “cosmopolitan” world
in which, as Post acknowledges, there are many dierent paths to the truth?46
Heinze resolves this tension by shiing the focus from the United States to the
global community as a whole, without giving up Post’s emphasis on democratic
legitimacy.
Moreover, Heinze is unafraid to make critical comments about political and
social institutions in the United States. In response to Richard Posner’s argu-
ment tracing European hate speech laws to “the less democratic cast of Euro-
pean politics,”47 Heinze asks: “Is democracy in Alabama or Mississippi some-
thing other than a ‘newcomer’? Do the histories of Denmark or the Netherlands
reveal a ‘less democratic cast’ than the histories of Texas or Georgia, or indeed
41 Ibid., pp. 78–80.
42 Post, Racist Speech, pp. 279–285 (stating the general principle that speech restrictions in
the public discourse are illegitimate) and p. 301 (stating that group harm is the price indi-
viduals may need to pay for “the political constitution of community identity”).
43 Ibid., p. 289 (allowing hate speech bans in employment settings) and pp. 317–25 (suggest-
ing there may be a role for banning hate speech in educational settings).
44 Jacobson, Arthur, Schlink, Bernhard. Hate Speech and Self-Restraint. In Herz, Michael,
Molnar, Peter (eds). Rethinking the Content and Context of Hate Speech: Regulation and
Responses, New York: Cambridge University Press, 2012, pp. 217–41(describing similari-
ties in US and European regulation of hate speech in the workplace and on television);
Bleich, Erik. e Freedom to be Racist? How the United States and Europe Struggle to Pre-
serve Freedom and Combat Racism. Oxford: Oxford University Press, 2011, pp. 106–33
(describing similarities between European hate speech bans and US anti-discrimination
laws).
45 While recognizing that “rst amendment doctrine is neither clear nor logical,” Post, Racist
Speech, p. 278, he nevertheless argues that the debate over hate speech regulation “ought
not to be settled without serious engagement with the values embodied in that doctrine.”
Ibid., p. 279.
46 At times, the conict leaves Post le standing on the sidelines, rather than making judg-
ments about the balances struck between free speech and hate speech in other societies.
See Kahn, Why Do Europeans Ban Hate Speech?, pp. 581–83.
47 Heinze, Hate Speech and Democratic Citizenship, p. 12 (quoting Posner, Richard. e
Supreme Court, 2004 Term—Foreword, Harvard Law Review, 2005, vol. 119, p. 86
(emphasis added by Heinze)).
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of Connecticut or Illinois?”48 e problem, according to Heinze, with this type
of celebratory analysis is not whether it is correct but that the “trophy” for free
speech liberalism, “ends up being awarded to a land steeped in corporate domi-
nance, military adventurism, botched death sentences, abusive incarceration
and police brutality.”49 Later, when critiquing the idea that political legitimacy
should depend on the popularity of an institution, Heinze asks: “In the Southern
US, slavery and then racial segregation once enjoyed ‘popular support’ in white
majority states. Did those institutions therefore become legitimate?”50
As someone in the United States living through mass incarceration, police
brutality – and now the Trump presidency – I nd Heinze’s frank critiques of our
political and social problems refreshing. Heinze also deserves credit for break-
ing free from the originalist taint of Post’s argument. America is not the Ur-
democracy, or the fabled city on a hill;51 rather, the United States is a democratic
country with its own problems. In this regard, it is no dierent from its demo-
cratic friends France, Canada, the United Kingdom – or any other country on
the Economist’s index of democratic states.52 America’s constitutional moment
may be foundational for the United States; but from a global perspective it is not
foundational for the justication of freedom of speech – it is merely one way to
reach Nirvana. Nothing more, nothing less.
4 America in the Age of Trump – Still an LSPD?
Heinze’s untangling of free expression from a discourse of American trium-
phalism is likely to appeal to those supporters of free speech who have doubts
about the suitability of the United States as a role model of free expression. At
the same time, Heinze’s LSPD model raises questions about whether, aer the
2016 elections and the rise of Donald Trump, the United States is still a “long-
standing, stable, prosperous democracy.” Might it, instead, be facing its own
“time of troubles”? Sitting in the United States, watching journalists face felo-
ny charges for covering Trump’s inauguration, I wonder about this.53 Here, the
48 Heinze, Hate Speech and Democratic Citizenship, pp. 12–13.
49 Ibid., p. 13.
50 Ibid., p. 44.
51 For instance, Post argues – without much documentation – that “the ability to forge new
communities” is a trait that is “quintessentially American.” See Kahn, Why Do Europeans
Ban Hate Speech?, pp. 574–75 (quoting Post, Racist Speech, p. 294, n.145).
52 Interestingly, three of the top four countries on the list are from Scandinavia (Norway,
Sweden and Denmark), Heinze, Hate Speech and Democratic Citizenship, p. 70, a region
that – for all its democratic institution building – also has issues with welcoming Muslim
migrants, as the Danish cartoon controversy demonstrates. See Kahn, Robert, e Dan-
ish Cartoon Controversy and the Exclusivist Turn in European Civic Nationalism, Studies
in Ethnicity and Nationalism, 2008, vol. 8, no. 3, pp. 528–34 (describing anti-immigrant
measures in Denmark in the years leading up to the controversy).
53 Bromwich, Jonah Engel. Felony Charges for Journalists Arrested at Inauguration Pro-
tests Raise Fears for Press Freedom. New York Times, 25 Jan. 2017. [online] <https://
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democratic legitimacy argument – both Post’s version and Heinze’s renement
– seems to come up short: If one believes the United States is entering an era
of “so authoritarianism,”54 wouldn’t protecting speech be more important than
ever? More generally, does the democratic legitimacy model which was born in
the 1980s and 90s,55 a time when democracy was riding on the crest of a “third
wave” 56 that was supposed to carry democracy to all corners of the globe, have an
answer for the age of Trump?
e model might not, but Heinze does. e answer relates to a second admi-
rable feature of Hate Speech and Democratic Citizenship, namely the depth of
Heinze’s arguments. For example, he organizes his arguments for and against
speech regulation into deontological and consequentialist categories. Banning
hate speech might good or bad in and of itself; or the diculty in restricting
or tolerating hate speech might be practical in nature. 57 While Heinze is not
the rst person to view speech regulation in this manner, his approach is note-
worthy for its rigor. Indeed, one of the most impressive qualities of Hate Speech
and Democratic Citizenship is its rich, detailed typography of arguments for and
against hate speech regulation.58 Not only do these give Heinze’s book an ency-
www.nytimes.com/2017/01/25/business/media/journalists-arrested-trump-inauguration.
html?_r=0> Accessed: 22.06.2017. e journalists were arrested because they were in an
area where a car had been set on re. Ibid. e charges against four of the six report-
ers arrested were quickly dropped. See Stack, Liam. Felony Charges Dropped against 4
Reporters Arrested at Inauguration Protests. New York Times, 30 Jan. 2017. [online] <htt-
ps://www.nytimes.com/2017/01/30/us/journalists-arrested-inauguration-charges.html>
Accessed: 22.06.2017. at said, the incident raises worrisome questions about the scope of
press freedom in the United States, a trend reinforced by eorts across the nation to enact
laws making protestors liable on felony charges for violent acts and property damage, even
when done by outsiders. See Opinion: Arizona Republicans Want to Apply Racketeering
Law to Protests. Can Someone Introduce em to the 1st Amendment?, LOS Angeles Times,
24 Feb. 2017. [online] <https://www.latimes.com/opinion/opinion-la/la-ol-arizona-pro-
test-1stamendment-20170224-story.html.> Accessed: 22.06.2017.
54 FRUM, David. How to Build an Autocracy. e Atlantic, March 2017. [online]. <https://
www.theatlantic.com/magazine/archive/2017/03/how-to-build-an-autocracy/513872/>
Accessed: 22.06.2017.
55 Post’s article, “Racist Speech”, was published in 1991 – two years aer the fall of the Berlin
Wall. More generally, there is a natural t between the supposed global triumph of lib-
eral democracy celebrated by Fukuyama and the triumph of democratic legitimacy as a
rationale for justifying speech. With democracy on the march in Latin America, Africa and
Eastern Europe, was there any reason to think that a theory of speech protection based on
democracy would be anything less than global as well?
56 Huntington, Samuel P. e ird Wave: Democratization in the Late Twentieth Century.
Norman, OK: University of Oklahoma Press, 1991.
57 Heinze, Hate Speech and Democratic Citizenship, p. 34 (using a chart to outline deontologi-
cal and consequentialist arguments for and against hate speech).
58 For example, Heinze concludes his book with a list of 20 separate arguments for hate
speech regulation and his opinion as to why they are wrong. Ibid., pp. 208–15.
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clopedic quality, they also let him raise concerns about speech regulation that do
not rely on the democratic legitimacy argument.
In this regard, the democratic legitimacy argument provides a oor of free
speech protection – longstanding, stable prosperous democracies should not
censor – but not a ceiling. An insuciently democratic society might have a
right to punish speech on security grounds, but it need not do this. ere are
also pragmatic arguments for protecting free speech, ones Heinze highlights
in a compelling section of his book entitled “Consequentialist Oppositionism
Revisited: Harms of Bans?”59 Here Heinze argues, among other things: (1) that
speech restrictions will still allow bigots to express the same ideas in slightly
more guarded language – in eect “tutoring” extremist groups;60 (2) alterna-
tively, potential bans will drive potential bigots underground, where they will be
harder to monitor;61 and (3) bans will likely fall most heavily on “disempowered
target groups.”62 While these arguments are not entirely new – Nadine Stros-
sen, for instance, raised the concern about targeting minorities decades ago63 –
Heinze presses his point home with a forcefulness and a sensitivity to the power
of words to do harm. For example, Heinze notes how extremist groups, tutored
by hate speech bans to act appropriately, will make comments about Islam as a
religion that, in reality, target Muslims as an ethnic group.64
For citizens of wavering LSPDs, lapsed LSPDs, or countries simply struggling
to become democratic in the rst place, this separation of deontological and con-
sequentialist arguments for speech regulation oers comfort in an age of rising
right-wing populism across the United States and Europe.65 At the same time,
Heinze’s consequentialist arguments operate independently of his democratic
legitimacy theory. In theory, for example, Heinze’s warning that states will use
bans against minority groups applies with equal force in the LSPD context and
the non-LSPD context. Could one, however, make an argument that – in an age
of increasing autocracy and authoritarianism – freedom of speech is even more
important in an imperfectly democratic state than it would be in an LSPD? More
narrowly, might one argue that the risk of the state using speech restrictions to
stie dissent is greater in such a circumstance?
59 Ibid., pp. 145–53.
60 Ibid. p. 145 (for example, a bully that previously called his target “fatso” will use “beauty”
instead).
61 Ibid., p. 146.
62 Ibid. p. 152.
63 Strossen, Nadine. Regulating Racist Speech on Campus: A Modest Proposal, Duke Law
Journal, 1990, pp. 554–55.
64 Heinze, Hate Speech and Democratic Citizenship, p. 151.
65 For an overview of the situation in the aermath of Trump’s electoral victory, see Askenas,
Jeremy, Aisch, Gregor. European Populism in the Age of Trump. New York Times, 5 Dec.
2016. [online] https://www.nytimes.com/interactive/2016/12/05/world/europe/populism-
in-age-of-trump.html?_r=0 Accessed: 22.06.2017.
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Here Heinze oers some interesting insights. In allowing non-LSPDs to pun-
ish hate speech, Heinze had in mind societies with “active inter-group rivalries
and inadequate means to pacify them”, where speech restrictions might be a “nec-
essary evil.”66 His paradigmatic example is Northern Ireland, where the “time of
troubles” justied British imposition of hate speech bans, albeit at the price of
concluding the Britain was no longer an LSPD.67 But in many divided societies
(including the United States), there is no higher power, no Britain, to impose
order. Under these circumstances, any legitimacy hate speech bans gain on the
basis of state security, is lost because the state no longer represents all groups
in society. Is the Turkish ban on acknowledgement of the Armenian genocide
justied because Turkey is not an LSPD?68 Or, as is more plausible, is the ban
illegitimate, because by the very enactment of the law, the Turkish government
excludes Armenians from full citizenship? Likewise, to the extent Trump suc-
cumbs to the extreme right-wing elements in his movement, and moves towards
explicit white supremacy,69 should he get the benet of the greater governmental
powers oered to non-LSPDs in conict-ridden societies?
To be fair, part of the limits of Heinze’s theory is a function of the rapid change
of conditions on the ground, in the United States and elsewhere. A few years ago,
Frederick Schauer re-examined the idea that false speech might have harmful
consequences.70 To show the potential harm of false news, Schauer used a wide
range of examples. While some of these were political (“President Obama was
born in Kenya,” “President Bush knew in advance of the 9/11 attacks”),71 others
were not. For example, Schauer described those “who promote…diet slippers
and diet earrings as sure-re cures for obesity.”72 Schauer wrote his article before
“fake news” concept became associated with the rise of Donald Trump. To put it
another way, Schauer wrote at a time when the United States was, to all appear-
ances, a healthy, functioning LSPD. While Schauer chose his examples in part to
demonstrate that Holocaust denial was not a special case – that all false informa-
tion might theoretically cause harm73 – he did not linger on the Kenya and 9/11
66 Heinze, Hate Speech and Democratic Citizenship, p. 80.
67 Ibid., p. 81.
68 Article 301 of the Turkish Penal Code, which bans speech that “insults” Turkey, has been
used to punish recognition of the Armenian genocide. For more, see Tate, Janisha. Turkey’s
Article 301: A Legitimate Tool for Maintaining Order, Or a reat to Freedom of Expres-
sion? Georgia International and Comparative Law Review, 2008, vol. 37, p. 181.
69 For an argument that the Trump administration is already starting to embrace white nation-
alism, see Bouie, Jamelle. Government by White Nationalism is Upon Us. Slate, 6 Feb.
2017. [online]. <http://www.slate.com/articles/news_and_politics/cover_story/2017/02/
government_by_white_nationalism_is_upon_us.html.> Accessed: 22.06.2017.
70 Schauer, Frederick. Social Epistemology, Holocaust Denial and the Post-Millian Calculus.
In Herz, Michael, Molnar, Peter (eds). Rethinking the Content and Context of Hate Speech:
Regulation and Responses, New York: Cambridge University Press, 2012, pp. 129–43.
71 Ibid., p. 140.
72 Ibid.
73 Ibid. pp. 142–43.
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points because they were not politically salient. Today, when the President of the
United States claims – without evidence – that millions voted illegally against
him,74 or that President Obama wiretapped his campaign,75 “fake news” is a
more relevant concept – one tied to deeper questions about the strength of dem-
ocratic institutions in the United States. Consequently, Schauer’s article – while
very informative – is likely the beginning, rather than the end, of the discussion
about “fake news.”
I rst read Hate Speech and Democratic Citizenship in May 2016 and enjoyed
it thoroughly. It is the book I wish I wrote, and a book to take to a desert island.
Re-reading the book in March 2017, I still enjoyed it; but something is missing.
e Washington Post now runs the words “Democracy Dies in Darkness” on its
masthead.76 If democracy is dying – or is facing a mortal risk – the LSPD theory
tells me that it can legitimately impose restrictions on hate speech as a means of
self-protection.77 I get that. But at a time when President Trump has declared the
media “the enemy of the American people”78 there is a need for a theory of free
speech (and hate speech regulation) that applies to states that are incompletely
democratic, or at risk of slipping away into authoritarianism.
at said, Heinze’s robust defense of democratic prerogative represented by
the LSPD concept is critical, not merely as an empirical concept but an aspira-
tional one as well. e United States may indeed be in the midst of a “time of
troubles” but if it wants to return to the LSPD ranks, it had best start acting like
one.79 Meanwhile, Heinze’s forceful, nuanced defense of free speech on conse-
74 Liptak, Kevin, Merica, Dan. Trump believes millions voted illegally, WH says – but oers
no proof. CNN, 25 Jan. 2017. [online] <http://www.cnn.com/2017/01/24/politics/wh-
trump-believes-millions-voted-illegally/> Accessed: 22.06.2017.
75 Staglin, Doug, Guadiano, Nicole. Trump, without evidence, accuses Obama of wiretapping
him; “Simply false, Obama spokesman says. USA Today, 4 Mar. 2017. [online]. <http://
www.usatoday.com/story/news/2017/03/04/trump-accuses-obama-wiretapping-him-
before-election/98734316/> Accessed: 22.06.2017.
76 Farhi, Paul. e Washington Post’s new slogan turns out to be an old saying, Washington
Post, 24 Feb. 2017. [online]. <https://www.washingtonpost.com/lifestyle/style/the-wash-
ington-posts-new-slogan-turns-out-to-be-an-old-saying/2017/02/23/cb199cda-fa02-
11e6-be05-1a3817ac21a5_story.html?utm_term=.4a17cd33243b> Accessed: 22.06.2017.
77 Heinze, Hate Speech and Democratic Citizenship, pp. 71–72 (describing emergency sce-
narios).
78 See Johnson, Jenna, Gold, Matea. Trump calls the media “the enemy of the American
People.” Washington Post, 17 Feb. 2017. [online] <https://www.washingtonpost.com/
news/post-politics/wp/2017/02/17/trump-calls-the-media-the-enemy-of-the-american-
people/?utm_term=.d9227654b168> Accessed: 22.06.2017.
79 Interestingly, because Heinze grounds the defense of speech in citizen prerogatives in a
well-functioning democracy, the task ahead is less about protecting speech – which is a
byproduct of an LSPD. Instead, it is about ensuring that the country nurtures a demo-
cratic culture that gives citizens, and society at large, the strength to protect disadvantaged
groups without resorting to speech bans. Heinze, Hate Speech and Democratic Citizenship,
p. 72.
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quentialist grounds80 is an excellent starting point for how to think pragmati-
cally about freedom of speech in an age when the civic culture of democracy may
be wavering. As such Hate Speech and Democratic Citizenship is indeed a book
for the age of Trump.
References (alphabetical order)
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80 Ibid., pp. 145–53. Perhaps the most obvious point of contact with the current situation is
Heinze’s concern about government misuse of speech restrictions. Ibid., p. 151. Equally
powerful, however, is his idea that speech restrictions are ineective because they “tutor”
target groups to use coded language that, ironically, can be more harmful because it is
less obviously oensive. Ibid., pp. 149–51. is oers both argument against state use of
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as for example, when the Trump administration was criticized for failing to list the Jews
as victims of the Holocaust. Solomon, Daniel L. Trump Doesn’t Mention Jews in Holo-
caust Remembrance Day Message, Fast Forward: Quick reads through a Jewish lens, 27 Jan.
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in-holocaust-remembrance-day-message/> Accessed: 22.06.2017. On a larger scale, how-
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to Congress, which won kudos from his critics for its supposed moderation even though it
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