| As today's world continually moves to a more unified state, it is important to examine the various national and international approaches to freedom of expression. This thesis provides a comparison of the protection afforded to expression in both the United States and the European Union member states, with a special emphasis on the areas of hate speech, political speech, and commercial speech. At this time, the United States seems to have a stronger tradition of protecting freedom of expression than most European Union nations.;Both the United States and European Union member states provide significant protection for political speech. However, the United States provides a much higher level of protection for political advertising than is afforded in most European Union nations. Likewise, the United States provides significantly greater protection for commercial speech than is provided by most European Union member states.;In the future, it will be interesting to see whether the United States and Europe develop a more similar approach to freedom of expression or whether each will retain its individual approaches. In an age when the impact of court decisions is often world-wide and the publication of information is not limited to the nation of origin, it seems likely that laws governing freedom of expression will eventually begin to transcend national boundaries. Supporters of freedom of expression would do well to understand the merits and drawbacks of different approaches to regulating expression so freedom of expression can be adequately safeguarded in the future.;In the United States, scholars generally consider content-based regulation of hate speech to be impermissible under the First Amendment. However, the European Court of Human Rights has found restrictions on hate speech to be valid under the limitations on freedom of expression present in the European Convention on Human Rights. |
