As a counterexample, in Europe, no company can fire an employee for "perpetuating gender stereotypes", or any other opinion, while in the US it seems quite easy to fire people for any reason.
I don't have much insight into European companies and how strongly they protect speech as a matter of policy, but rulings by the EU have been extremely discouraging. Here are some examples:
1. The EU's "right to be forgotten" can compel the removal of content that is both true and relevant. [1] In the US, my right to publish true facts about you trumps your right to have them swept under the rug.
2. The EU can compel publishers to remove content they deem "hate speech." [2] If you look up the EU's definition of hate speech, it actually sweeps broadly into what the US would call protected speech. For example, Germany's "incitement of popular hatred" [3] can be used to prevent newspapers from advancing the argument that migrants are disproportionately likely to commit crimes. Since there is no truth defense against hate speech accusations (unlike libel in the US), a newspaper that is dragged into court on hate speech charges couldn't defend itself by proving that what it wrote was true.
[1] http://www.spiegel.de/international/business/court-imposes-r...
[2] https://www.theverge.com/2017/3/14/14920812/germany-facebook...
Nonetheless, alone they are not enough to prove the point. I could go and find other cases for the US too.
If we look, though, at the Freedom of the Press report of Freedom without Borders, the US comes after all Western Europe countries (except Italy): https://rsf.org/en/ranking
I can tell you that, in the US, it's extremely difficult to prevent a newspaper from publishing things the government doesn't want published (see New York Times v. United States), or for a private party to successfully sue them (see New York Times v. Sullivan). It has happened, but it's very rare and there is nothing analogous to Europe's sweeping "hate speech" laws that force newspapers to self-censor anything critical of migrants.
The thing is, what you say about this kind of law is probably true. But freedom of speech goes further than that and, as you mentioned in your original comment, it's not just a matter of laws.
2. The EU can compel publishers to remove content they deem "hate speech." [2] If you look up the EU's definition of hate speech, it actually sweeps broadly into what the US would call protected speech.
Some coutries deem, for example, Holocaust denial a criminal offense. You can argue if this is good or bad. But let me assure you that Europe is not that hellhole where you not dare say anything.
England, with its insane libel laws may be an exception, but soon it's anyway no more part of the EU.
In my opinion, this is also far beyond the "good" free speech (as in, free statement of opinion and political dissent) and into the realm of trying purposefully to do damage, by using speech in bad faith, which I think should not be free at all. Then again, e.g. cursing at police officers seems to be legal in the US as well, so I guess this is a cultural difference :)
Bull. Shit.
Tabloids still run ridiculously xenophobic and bigoted headlines in Germany even if we're not quite at the level as e.g. UK tabloids.
Saying "there's a correlation between the refugee crisis and a rise in crimes" is protected speech in Germany. Saying "those donkey fuckers crossing our borders must be shot on sight and their children too" is hate speech.
We're talking about the kind of statements that get showcased on sites like this: https://perlen-aus-freital.tumblr.com
In the US it's acceptable for politicians calling for undesirables like Snowden or Assange to be murdered. In Germany this kind of rhetoric would land you in jail for inciting violence and instigating criminal behavior.
Also in Germany it's forbidden to bring weapons (including "defensive weapons" like shields or gasmasks) to demonstrations. In the US you have neo-nazis and antifa running into each other with riot gear and bashing each others' heads in with lengths of wood. Not to mention paramilitaries parading in camouflage with military-looking gear and firearms.
Incidentally, German riot police doesn't use military equipment and actual violent protests are usually confined to anarchists using improvised weapons to cause property damage.
> Since there is no truth defense against hate speech accusations
Again, bullshit. If you use Nazi symbology, loudly shout "gas the jews" and do the salute, you know what you're doing. Stop pretending we're talking about scientific discourse here.
This isn't about some economist or sociologist publishing troubling research findings or level-headed reporting on anything of the sort. This is about bigots venting their hatred and tabloids abusing scare tactics to sell more copies.
If you say that's all that gets called "hate speech" you're being deliberately dishonest.
> Stop pretending we're talking about scientific discourse here.
I don't have to pretend.
Which part of that offensive statement is 'hate speech':
a) Donkey Fucker
b) must be shot on sight
c) [their children] must be shot on sight
In US, a) cannot be restricted by the govt. b) and c) can be, provided the govt prove that it was the same thing as asking your right hand to pull the trigger (as it's a clear and present danger).
Moreover, if someone does shoot kids and immigrants, and it was shown that this someone was motivated by your statements, then you can be sued under a civil lawsuit for millions by the family of the people who died.
> In Germany this kind of rhetoric would land you in jail for inciting violence and instigating criminal behavior.
In US too, inciting violence and instigating criminal behavior could land you in jail, except American definition of 'inciting violence and instigating criminal behavior' is a lot different than European definition.
A politician calling drone attacks on Snowden or Assange isn't 'inciting violence and instigating criminal behavior' in US.
A politician picking up the phone and asking his brother who is a drone operator to do a drone attack on Assange or Snowden, would be.
"Donkey fucker" is a racial slur. Most of the racial slurs used in these comments don't translate well, e.g. "oil eye". It's in the same register of language as the n-word in English.
It may not come across that well in English but there's a direct call to action: "shoot them and their children", basically. It's not specifically directed at anyone. Charitably it could be read as "we should enact policies so soldiers do this" but less charitably it's directly calling for people to go out and shoot other people -- which is inciting violence.
I'm fairly certain going on national TV and offering a significant monetary reward to anyone who murders Snowden/Assange/Trump would be illegal even in the US. The only difference is that Germany doesn't require a tangible reward for that to be illegal.
But hey, what do I know, it's not like the US is at risk of bringing lynchings back or something.
https://en.wikipedia.org/wiki/Lynching_in_the_United_States#...
EDIT: Oh, and the obvious difference: aside from a strict loyalty to international Human Rights, the German constitution centers around the idea of the indelibility of human dignity. Dehumanizing people is always unconstitutional and promoting hatred around racial identity or ethnic background is almost always dehumanizing.
German court upholds its ban on comedian's Erdogan poem
Not the exact same business situation, but is that an example? Guy can't make a living off of his comedy because he's mocking a dictator.
The whole purpose of the poem was to get banned.
Mr Boehmermann's lawyer said the ruling went against "artistic freedom".
"We believe that the court's decision in its concrete form is wrong, given that it deems those parts dealing with Erdogan's approach to freedom of expression to be acceptable," said Christian Schertz.
per one of the links in that article
That kind of rhetoric trivializes how repressive the Erdoğan regime really is. With all its faults, Germany hasn't locked up thousands of innocent people on shady claims of conspiracy or terrorism, or shut down independent TV stations or newspapers. Germany also hasn't abolished its strict division of power and given the president or chancellor absolute power.
And so would you
Stop pretending we believe your rethorical bullshit
I've actually met ex-nazis in Germany and I don't believe the causality you're proposing holds up.
Yes, neo-nazis think the "jews" are running the country and keeping them down, but this is no different from how the antifa think the "fascists" are doing the same.
The recent rise of nationalism in Germany actually has more to do with both major parties having become indistinguishable in many cases and "moderates" flocking to the extremes to "punish" the government.
It's a lot like trolls on 4chan spreading racist memes "for the lulz" until they end up having become actual white supremacists participating in Nazi rallies instead of merely shitposting on the Internet.
Right-leaning "moderates" vote for the right-wing extremists (NPD if you're really angry or AfD if you are more of a realist) out of spite and then fall for the rhetoric as they continue exposing themselves to their messages.
The only effective treatment against this disease seems to be constant exposure to other people with other ideas coming from other walks of life.
Yes, there's an East/West divide in neo-Nazi density in Germany, but it's also very much a rural/metropolitan divide. If all the people around you look, talk and think like you, everything different becomes a threat to your way of life.
He's also still very much able to "make a living off of his comedy". His "Schmähkritik" (the title of the piece as well as the crime reciting the poem would constitute) was just a single one-off performance on a publicly funded TV show.
Also, in the US, often companies offer you money to not sue them when they fire you. Doesn't mean the firing is legal, simply it is easier for everyone involved that way.
Here the guy was likely fired for saying that he witnessed discriminating hiring practices, i.e. quotas, to improve diversity metrics. And firing a whistleblower is illegal in the US as well. Most likely they will reach an agreement (or they have already reached). The guy will get some money and everyone will move on. Much easier than getting involved with legal stuff for both, google and the engineer.
What also matters is the practicalities and cost of redress and that varies across Europe. It's not the liberal paradise across the board as some suggest.