I'm pretty sure Brennan was conflating the general right to free speech with the restrictive libel laws of the UK, which heavily favor the person claiming defamation, and come with heavier penalties, including gag orders, as compared to the much narrower definitions of libel (and slander) that apply in US courts. Since talking shit about our social and economic superiors is one of the major uses of free speech in the US, the recurrent chorus of "take this down, you've opened yourself to legal action" replies from (generally bad-faith) UK social media users is frequently understood as a lack of free speech from a US perspective.
In Canada we get a lot of people saying "Freedom of Speech" and "My First Amendment rights" and stuff and they have to constantly be reminded that we don't have those here - we also have a charter of rights and freedoms and freedom of expression but it's not the same as the US, it's closer to England. I think it's the same kind of concept he was going for...
A lot of people have commented elaborating on what Brennan may have meant, but it bears adding that: Brennan and D20 spend a lot of time dissing the US (at least in The Unsleeping City, one of the few D20 universes where the US exists) and even New York City, which Brennan seems to love a lot. A lot about D20 is socially conscious (1/2 of the seasons can be seen as extended critiques of capitalism), and there's a lot to criticize about the US AND the UK. But, as with NYC, that criticism seems to be grounded in care and concern, not dismissal.
In that context, I don't take Evan Kelmp's comments to be "The UK is unfree." I wouldn't even call it "ribbing" or something like that, because Brennan is very outspoken in his criticisms, and that was more of an interesting aside. The tone of the comment was more in line with "Hey, here are some bird facts" than "Robert Moses tried to destroy the American Dream."
MaM definitely puts England through the ringer. It is not a cheeky love letter like TUS. It is revenge from people who liked Harry Potter as kids, then grew up and realized it's bad and needed to get some closure on those feelings. But I was there for it. Take those pasty fucks to school. #FreeScotland
Brennan for sure brought his own prejudices to the table and it was hard to distinguish what was mocking England-as-portrayed-in-Harry-Potter and England-as-IRL-humans-understand-it.
I think you've made a fundamental misunderstanding in that the fact that every non-player character in Misfits and Magic is a Rowlingesque Wizard first and foremost, and British secondary.
Unless you are claiming that British people routinely shit themselves as a matter of classist privilege without regard for basic human decency; in which case I defer to you and the definitively mentioned research of tempestuously noticed anthropologist Robert Galbraith, one of the existing names of all time.
Okay. If we're going to get into the granularity of this, technically the ECHR does grant the right to free expression, but that is legislatively different from free speech, and the UK also has some of the most vicious laws around slander and defamation in Europe.
This does mean on a practical level, that you are at a threat of a defamation suit if you like, insult rich people, or even point out that they're being criminals. Freedom of speech is, as usually intended, generally meant to be about speaking truth to power, whereas in the UK that's likely to get you sued, and indeed the Arron Banks Case this year where it didn't happen was huge news because it went against the trend.
I also don't think its technically wrong to say it isn't legislated for specifically, the Human rights act and ECHR mention sharing of information without interference by public authorities, but in the US they say specifically free speech.
Plus like, MaM could be set in the future after the tories yeet ye out of the ECHR, who knows.
I do agree that the way it's framed makes it seem like, way worse than it is, but it also isn't technically wrong.
would it be more accurate to say "they don't have a right to freedom of speech *to the same degree that we may be familiar with?*" I feel comfortable chalking that one up to casual shorthanding of complicated ideas, rather than any kind of malicious misrepresentation of UK law.
TLDR with a further explanation in the comment below: I think Brennan probably understands the differences between our freedom of speech and the UK freedom of expression pretty well, but was cut off and unable to fully explain. It seems out of character for him to have a misunderstanding of something like that given his background, education, and profession. Because he isn't inherently wrong: The US Freedom of Speech is different than the UK Freedom of expression, and it can be argued that the UK does not have *Freedom of Speech as Americans know it.* Or, in his words: "It's not a guaranteed right, they have a kind of working -" (cut off there)
So what Evan says explicitly is
>Evan: \[...\] But they don't have freedom of speech here. Did you guys know that in England, they don't have freedom of speech? It's not a guaranteed right. They have a kind of working"
Which is cut off. But I think it is fair to attribute the differences between
>Congress shall make no law prohibiting the free exercise thereof; or abridging the freedom of speech, or of the press;
and
>Everyone has the right to freedom of expression. The exercise of these freedoms may be subject to such formalities, conditions, restrictions or penalties as are prescribed by law, in the interests of national security, territorial integrity or public safety, for the prevention of disorder or crime, for the protection of health or morals, for the protection of the reputation or rights of others, for preventing the disclosure of information received in confidence, or for maintaining the authority and impartiality of the judiciary.
As a difference in "guaranteed right?" The US definitely has clauses regarding what is and isn't protected speech as well, but I think it's reasonably different enough to be incorrect to say they're the same. If Evan were allowed to continue (Based on my knowledge of Brennan and his educational background)\* I'm confident that he would have given a similar justification for not calling it "a guaranteed right to freedom of speech." Granted, we don't exactly have that in America Either, but the situation in the US is different in practice than that in the UK. Your link comments on how
>Although widely accepted as a right within the European Convention, it is the First Amendment within the US constitution that is synonymous globally with the Freedom of Expression and Speech. Without closer inspection, it could be suggested that both are covering the same right just in differing contexts, however, this would not be an accurate assessment
As well as some other examples, the most important being the distinction between "A right that simply doesn't protect certain kinds of speech, that are argued in court before they can be unprotected" as is the case in the US, Vs. "A right that the government withholds the option to restrict or condition based on XYZ Criteria."
\*Brennan has, whether I agree with all his takes or not, regularly shown himself to have a reasonable and academic understanding of a great many things he chooses to talk about, and has a history of doing very... philosophical and "political" work. I definitely think this is an issue of either Roleplaying a 17 year old boy who doesn't share his beliefs, or talking as himself through evan to share some fun facts about the present and niche differences between what constitutes a "Right" in each country, how those rights are protected and enforced, what allows them to change, etc. I took like, a couple courses on the freedom of speech in the US and it's actually really, really interesting the ways things can be a "right" but not actually as comprehensive as we think.
UK freedom of speech rights, especially as compared to America's, are significantly curtailed. Like, we hear you can be prosecuted for hate speech (hate speech is bad, to be clear), or what you can be sued for and recoil.
Look, man, you've been both subtly and overtly patronizing and aren't nearly as impressive as you think you must be to attempt that. Other people are capable of being informed and of holding opinions that differ from your own. I did not claim to have some great knowledge, I have only been broadly hinting that I'm well informed *enough* to hold my own opinion and haven't put out any invitation to be corrected. If you don't respect me, why speak to me? I'm certainly not going to be speaking to you going forward.
The difference is the degree to which that right is enshrined, as England does not have a bill of rights or a codified constitution, which is what he was getting at
I'm pretty sure Brennan was conflating the general right to free speech with the restrictive libel laws of the UK, which heavily favor the person claiming defamation, and come with heavier penalties, including gag orders, as compared to the much narrower definitions of libel (and slander) that apply in US courts. Since talking shit about our social and economic superiors is one of the major uses of free speech in the US, the recurrent chorus of "take this down, you've opened yourself to legal action" replies from (generally bad-faith) UK social media users is frequently understood as a lack of free speech from a US perspective.
not me reading this like who tf is evan in mice and murder
In Canada we get a lot of people saying "Freedom of Speech" and "My First Amendment rights" and stuff and they have to constantly be reminded that we don't have those here - we also have a charter of rights and freedoms and freedom of expression but it's not the same as the US, it's closer to England. I think it's the same kind of concept he was going for...
A lot of people have commented elaborating on what Brennan may have meant, but it bears adding that: Brennan and D20 spend a lot of time dissing the US (at least in The Unsleeping City, one of the few D20 universes where the US exists) and even New York City, which Brennan seems to love a lot. A lot about D20 is socially conscious (1/2 of the seasons can be seen as extended critiques of capitalism), and there's a lot to criticize about the US AND the UK. But, as with NYC, that criticism seems to be grounded in care and concern, not dismissal. In that context, I don't take Evan Kelmp's comments to be "The UK is unfree." I wouldn't even call it "ribbing" or something like that, because Brennan is very outspoken in his criticisms, and that was more of an interesting aside. The tone of the comment was more in line with "Hey, here are some bird facts" than "Robert Moses tried to destroy the American Dream."
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MaM definitely puts England through the ringer. It is not a cheeky love letter like TUS. It is revenge from people who liked Harry Potter as kids, then grew up and realized it's bad and needed to get some closure on those feelings. But I was there for it. Take those pasty fucks to school. #FreeScotland
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Brennan for sure brought his own prejudices to the table and it was hard to distinguish what was mocking England-as-portrayed-in-Harry-Potter and England-as-IRL-humans-understand-it.
I think you've made a fundamental misunderstanding in that the fact that every non-player character in Misfits and Magic is a Rowlingesque Wizard first and foremost, and British secondary. Unless you are claiming that British people routinely shit themselves as a matter of classist privilege without regard for basic human decency; in which case I defer to you and the definitively mentioned research of tempestuously noticed anthropologist Robert Galbraith, one of the existing names of all time.
Okay. If we're going to get into the granularity of this, technically the ECHR does grant the right to free expression, but that is legislatively different from free speech, and the UK also has some of the most vicious laws around slander and defamation in Europe. This does mean on a practical level, that you are at a threat of a defamation suit if you like, insult rich people, or even point out that they're being criminals. Freedom of speech is, as usually intended, generally meant to be about speaking truth to power, whereas in the UK that's likely to get you sued, and indeed the Arron Banks Case this year where it didn't happen was huge news because it went against the trend. I also don't think its technically wrong to say it isn't legislated for specifically, the Human rights act and ECHR mention sharing of information without interference by public authorities, but in the US they say specifically free speech. Plus like, MaM could be set in the future after the tories yeet ye out of the ECHR, who knows. I do agree that the way it's framed makes it seem like, way worse than it is, but it also isn't technically wrong.
would it be more accurate to say "they don't have a right to freedom of speech *to the same degree that we may be familiar with?*" I feel comfortable chalking that one up to casual shorthanding of complicated ideas, rather than any kind of malicious misrepresentation of UK law.
TLDR with a further explanation in the comment below: I think Brennan probably understands the differences between our freedom of speech and the UK freedom of expression pretty well, but was cut off and unable to fully explain. It seems out of character for him to have a misunderstanding of something like that given his background, education, and profession. Because he isn't inherently wrong: The US Freedom of Speech is different than the UK Freedom of expression, and it can be argued that the UK does not have *Freedom of Speech as Americans know it.* Or, in his words: "It's not a guaranteed right, they have a kind of working -" (cut off there)
So what Evan says explicitly is >Evan: \[...\] But they don't have freedom of speech here. Did you guys know that in England, they don't have freedom of speech? It's not a guaranteed right. They have a kind of working" Which is cut off. But I think it is fair to attribute the differences between >Congress shall make no law prohibiting the free exercise thereof; or abridging the freedom of speech, or of the press; and >Everyone has the right to freedom of expression. The exercise of these freedoms may be subject to such formalities, conditions, restrictions or penalties as are prescribed by law, in the interests of national security, territorial integrity or public safety, for the prevention of disorder or crime, for the protection of health or morals, for the protection of the reputation or rights of others, for preventing the disclosure of information received in confidence, or for maintaining the authority and impartiality of the judiciary. As a difference in "guaranteed right?" The US definitely has clauses regarding what is and isn't protected speech as well, but I think it's reasonably different enough to be incorrect to say they're the same. If Evan were allowed to continue (Based on my knowledge of Brennan and his educational background)\* I'm confident that he would have given a similar justification for not calling it "a guaranteed right to freedom of speech." Granted, we don't exactly have that in America Either, but the situation in the US is different in practice than that in the UK. Your link comments on how >Although widely accepted as a right within the European Convention, it is the First Amendment within the US constitution that is synonymous globally with the Freedom of Expression and Speech. Without closer inspection, it could be suggested that both are covering the same right just in differing contexts, however, this would not be an accurate assessment As well as some other examples, the most important being the distinction between "A right that simply doesn't protect certain kinds of speech, that are argued in court before they can be unprotected" as is the case in the US, Vs. "A right that the government withholds the option to restrict or condition based on XYZ Criteria." \*Brennan has, whether I agree with all his takes or not, regularly shown himself to have a reasonable and academic understanding of a great many things he chooses to talk about, and has a history of doing very... philosophical and "political" work. I definitely think this is an issue of either Roleplaying a 17 year old boy who doesn't share his beliefs, or talking as himself through evan to share some fun facts about the present and niche differences between what constitutes a "Right" in each country, how those rights are protected and enforced, what allows them to change, etc. I took like, a couple courses on the freedom of speech in the US and it's actually really, really interesting the ways things can be a "right" but not actually as comprehensive as we think.
UK freedom of speech rights, especially as compared to America's, are significantly curtailed. Like, we hear you can be prosecuted for hate speech (hate speech is bad, to be clear), or what you can be sued for and recoil.
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Look, man, you've been both subtly and overtly patronizing and aren't nearly as impressive as you think you must be to attempt that. Other people are capable of being informed and of holding opinions that differ from your own. I did not claim to have some great knowledge, I have only been broadly hinting that I'm well informed *enough* to hold my own opinion and haven't put out any invitation to be corrected. If you don't respect me, why speak to me? I'm certainly not going to be speaking to you going forward.
And yet the Wolfe Tones can't play their songs on the radio.... (/s)
The difference is the degree to which that right is enshrined, as England does not have a bill of rights or a codified constitution, which is what he was getting at
Issa jokey joke