Cross-National Variation in Norms, Values, and Tolerance for Offensive Speech

• In Event: The Social and Emotional Foundations of Political Divisions

Abstract

The boundaries and limits of free speech in law and public opinion are a global issue. Freedom of speech is a defining feature of democracy, yet there is a growing body of opinion that certain kinds of speech must be limited or banned in order to defend democracy from hostile elements. In Western democracies, how and when to regulate “hate speech,” -- broadly defined as “abusive or threatening speech or writing that expresses prejudice on the basis of ethnicity, religion, sexual orientation, or similar grounds” - has emerged as a major political battleground. In this debate, freedom of expression and the dangers of censorship are weighed against the potential for hate speech to incite violence and harm the dignity, health, and opportunities of the individuals targeted by such speech.

Countries vary in the degree to which they place limits on speech. This paper focuses on the public’s tolerance for controversial speech in the United States, the United Kingdom, Canada, and Australia. Although these countries have a shared political heritage of British origin, they have developed different legal regimes regarding the protection of hate speech. A major contrast exists between the United States, where the First Amendment provides substantial protection of offensive speech, and Europe, Canada, and Australia where laws ban a wide range of speech, including public commentary that is deemed racist, homophobic, anti-Semitic, or Islamophobic. This is not to say that public and private institutions in the United States do not monitor and punish offensive speech, but litigation based on the First Amendment frequently curtails such activity.

Using nationally representative survey data collected in 2022, our research analyzes cross-national variation in public support for limiting offensive speech by comparing American, British, Canadian, and Australian levels of tolerance for controversial statements about race, gender, religion, and sexuality that, in many cases, have led to the successful prosecution of speakers in countries outside of the U.S. We include offensive statements directed at both right wing and left wing targets and also distinguish between “extreme” and “moderate” statements on the same subjects to assess the subjective boundaries of tolerance.

Our empirical presentation examines overall (aggregate) differences in tolerance among these countries as well as the underpinnings of political tolerance in socialization, political learning, norms and values, and individual psychology. In our previous research, (Chong, Citrin, and Levy, “The Realignment of Political Tolerance in the United States,” Perspectives on Politics, 2022) we showed that the elite consensus in favor of the principles in the First Amendment no longer are a clear norm. In American public opinion, public tolerance of hate speech has declined over the past half century and its traditional relationships with age, education, and ideology have diminished or reversed. We interpreted these shifts in terms of a social learning model in which the growing prominence and transmission of egalitarian norms through the media and other elite communications have eroded the prioritization of support for civil liberties.

A similar pattern of elite norms has emerged in our comparison countries as evidenced by the legal regimes developed there as well as by media coverage and developments in academia. Given the differences in political contexts and legal standards between the US and the UK, Canada, and Australia, we compare the relationships between tolerance and age, education, ideology, and other explanatory variables across all four countries to note similarities and differences in patterns of socialization and social learning. We also consider how variations across political cultures in the prioritization of values—freedom versus equality in particular—affects opinions about the protection of offensive speech, and how knowledge of one’s country’s actual law matters, a further test of the social learning model. Among the implications of this research is a better understanding of the impact of institutions and national cultures on the development of political tolerance in the mass public.

Authors

• Dennis Chong, University of Southern California

• Jack Citrin, University of California, Berkeley

• Morris E Levy, University of Southern California