Of course, as you say, this is the curse of generalizations. It's just the easiest way I've found to explain how legal systems which are superficially similar (

Of course, as you say, this is the curse of generalizations. It's just the easiest way I've found to explain how legal systems which are superficially similar (I live in an "english common-law" country), end up being wielded very differently. The other is a general trust of the justice system. "Hate speech" as a legal concept would be abhorrent in the US. 1A aside, it feels like no-one trusts the state to reasonably decide where the line between free speech & hate speech lays, so you simply don't allow it to - Whereas we're much more prone to allow judges to make these judgements. Of course there's exceptions, how boring the world would be if there weren't. (eg, "I know it when I see it" is a line most famously attributed to a Supreme Court Justice, while the concept behind it finds itself much more at home on the other side of the pond). But the trends seem clear. (This isn't to beat my chest and admire how much better we think we are - I do think both sides could stand to learn something from the other.)