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In my country, Germany, the media are only allowed to publish the name of a convict in cases of grave crime or when the crime is of special concern to the public. In minor cases the right of personality outweighs the public's right to information.


In the US, the constitution guarantees freedom of speech. It's very difficult to legally prohibit anyone from publishing anything.

https://en.wikipedia.org/wiki/First_Amendment_to_the_United_...

This why, btw, US news has so many lies. It's nearly impossible to regulate the media unless there is a constitutional change.


Germany’s constitution also guarantees freedom of speech. Both the US and Germany have exceptions.

For Germany - https://www.loc.gov/law/help/freedom-expression/germany.php

For the US - https://en.m.wikipedia.org/wiki/United_States_free_speech_ex...


> Germany’s constitution also guarantees freedom of speech. Both the US and Germany have exceptions.

No it does not.

> Congress shall make no law respecting an establishment of religion, or prohibiting the free exercise thereof; or abridging the freedom of speech, or of the press; or the right of the people peaceably to assemble, and to petition the Government for a redress of grievances.

There is absolutely no equivalent to this in the German constitution or anywhere else on the planet, the way it is phrased, applied and uphold by the US supreme court.


>> Both the US and Germany have exceptions.

> No it does not.

Bold claim. How does one square it with the exceptions documented in the article linked in GP's post?


I guess that's technically true. No other country's laws can restrict the kinds of laws the US Congress can make.


The better way to summarise would be to say that the Grundgesetz guarantees the freedom of expressing your opinion and views. It does not protect you when making false claims or lying.




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