The NYT quotes Mark Steyn in an article that emphasizes the unique strength of the American law of free speech:
“Canadians do not have a cast-iron stomach for offensive speech,”[said Jason Gratl, a lawyer for the British Columbia Civil Liberties Association and the Canadian Association of Journalists.] “We don’t subscribe to a marketplace of ideas. Americans as a whole are more tough-minded and more prepared for verbal combat.”...
A 1990 decision from the Canadian Supreme Court, for instance, upheld the criminal conviction of James Keegstra for “unlawfully promoting hatred against an identifiable group by communicating anti-Semitic statements.” Mr. Keegstra, a teacher, had told his students that Jews were “money loving,” “power hungry” and “treacherous.”
Writing for the majority, Chief Justice Brian Dickson said there was an issue “crucial to the disposition of this appeal: the relationship between Canadian and American approaches to the constitutional protection of free expression, most notably in the realm of hate propaganda.”
Chief Justice Dickson said “there is much to be learned from First Amendment jurisprudence.” But he concluded that “the international commitment to eradicate hate propaganda and, most importantly, the special role given equality and multiculturalism in the Canadian Constitution necessitate a departure from the view, reasonably prevalent in America at present, that the suppression of hate propaganda is incompatible with the guarantee of free expression.”