The US also has restrictions on 'free speech'. It's strange that the US is so passionate about protecting hate speech, but is similar to other places when it comes to libel or slander (which are similar to hate speech, in that they're about defamation). Similarly things like Free Speech Zones: 'you can say what you want, but you aren't allowed to say it in this public space'. There are a lot of nuances to 'free speech', it's not the black-and-white affair that many say it is.
If in one jurisdiction you can legally say everything you can say in another, and then also say other things too, then the first jurisdiction unambiguously has more free speech. There's not a lot of nuance, just a total ordering, from more free speech, to less.
'Hate speech' restrictions aren't primarily "about defamation" or even threats. Those are already handled by actual defamation and assault law, with stricter standards of harm.
'Hate speech' rules add extra penalties based on motivation or message. They aim to penalize when listeners are simply offended, and even when the speech is trivially true. For example, most verboten slurs against group X, when unpacked, simply mean "I see you as X and I dislike X" – which is almost always a self-certifying utterance, and reveals more about the speaker than the target. So let them speak.
Phrases like "Free Speech Zones" are a lot like saying that free speech is a 'nuanced' matter. Such words are a hint that something that's actually censorship, and unfree speech, is trying to pass itself off as 'free speech'.
most verboten slurs against group X, when unpacked, simply mean "I see you as X and I dislike X"
No, they don't mean just that. Most slurs against group X are "I see you as X, and I dislike X, and I want to prejudice people against X, reducing their opportunities". Hate speech is maligning a group to diminish them, and slander/libel is maligning an individual to diminish them.
There's not a lot of nuance, just a total ordering, from more free speech, to less.
This implies that 'free speech' is a sliding scale. It's not - it's polyvariate. Hence, nuance.
Edit: example: "You can say anything, you just can't criticise the king" versus "You can say anything, you just can't copy a company's mascot". Which of these two is "less free speech" than the other? How do you measure that? Does the king have more power over your life than companies do? Do you want to criticise the king more than you want to make a derivative work of Mickey?
"I see you as X, and I dislike X, and I want to prejudice people against X, reducing their opportunities"
Indeed, I accept your extension of such slurs' usual import.
The extended version is still a true statement, which accurately communicates the facts of the speaker's views and preferences about X, moreso than it actually defames X. So let slurs be said. When someone wants to say, "I am an idiot/bigot!", and that statement is true, why make that truth illegal?
And yes, there are many potential dimensions of free speech, as in your two reduced examples. But in practice the variables are highly correlated.
Remember the example that started this digression, fines for offensive tweets in the UK. That's not a different kind of 'free' speech, it's simply unfree speech in that dimension – and it's an accurate hint that speech is generally less-free in the UK than the US. (The UK is also notable in its plaintiff-friendly libel/slander laws and expansive secrecy/press-gag orders.)
Similarly, you justified 'hate speech' restrictions by tenuous analogy to defamation. And trademark/copyright are often enforced differentially to silence fringe expression.
A jurisdiction that penalizes one kind of speech is more prone to penalize others. The rationalizations and enforcement mechanisms become familiar, and build on each other. Each punishment of speech is the opposite of free speech, not some nuance of free speech.
The UK is also notable in its plaintiff-friendly libel/slander laws and expansive secrecy/press-gag orders.
And yet RSF still rates the UK as better than the US in it's annual Press Freedom Index (and has for years, IIRC). The US has plenty of gag orders when it comes to 'national secrets' and the like (as does my own country, Australia).
But yes, I agree that fines for tweets is not an example of free speech - but I was saying that speech is multipolar, not a continuum. Sure, in the UK, you can get fined for an offensive tweet. But in the US, there are some areas (8 states?) where you cannot state "I am gay" and legally hold political office.
Each punishment of speech is the opposite of free speech
Which implies that 'free speech' is a universal good. I would disagree - there are cases where free speech does nothing but harm. Westboro Baptist Church picketing funerals is a clear case. A funeral is a once-off event that cannot be repeated, and people are at their weakest. That picketing actually hurts people, directly, and intentionally. If instead they threw punches, there'd be no qualms about LEO's moving in and locking them up, but because they're doing psychological damage (and clearly intending to do so at people at their weakest, who have nothing to do with their gripe), it's considered a reasonable loss in defence of free speech.
The other difference between European and US ideals on free speech/hate speech is that Europe has seen close up and personal exactly the kind of horrors that come from letting hate speech progress unchecked. The WWII era is pretty painful for continental Europeans - they don't share the Anglo world's passion for reliving the glory days where we were unequivocably on the side of right, and we won. Europe suffered incredible pain from hate speech; something that the US has not had to endure. It's something to keep in mind when determining what you consider to be a workable level of freedom of speech.
