The social consequences of race | Social Science homework help HomeworkMarket How it works.Pricing.FAQ.Homework Answers.Log in / Sign up The social consequences of race Fahad502 hate_crime_paper.pdf Home>Social Science homework help>The social consequences of race Hate Crimes: A Critical Perspective Author(s): James B. Jacobs and Kimberly A. Potter Source: Crime and Justice, Vol. 22 (1997), pp. 1-50 Published by: The University of Chicago Press Stable URL: http://www.jstor.org/stable/1147570 Accessed: 27/12/2009 17:36 Your use of the JSTOR archive indicates your acceptance of JSTOR's Terms and Conditions of Use, available at http://www.jstor.org/page/info/about/policies/terms.jsp. JSTOR's Terms and Conditions of Use provides, in part, that unless you have obtained prior permission, you may not download an entire issue of a journal or multiple copies of articles, and you may use content in the JSTOR archive only for your personal, non-commercial use. 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Jacobs and Kimberly A. Potter Hate Crimes: A Critical Perspective ABSTRACT During the past decade, spurred by claims that the country is experiencing a hate crime epidemic, Congress and the majority of states have enacted laws increasing the punishment for crimes motivated by officially disfavored prejudices. Congress has also mandated a reporting system that aims to provide data on the incidence of hate crime. Some police departments have formed bias crime units. The upshot is the emergence of a new crime category and a new way to think about crime. The definition of hate crime, however, is fraught with problems, the federal data gathering effort has been completely unsuccessful, and enforcement of the hate crime laws has been minimal. Creation of a hate crime category fills political and symbolic functions but is unlikely to provide a useful indication of the state of various prejudices or to reduce crime generated by prejudice. Indeed, deconstructing criminal law according to the dictates of "identity politics" might exacerbate social divisions and conflict. The terms "hate crime" or "bias crime" have established their places in the crime and justice lexicon and appear routinely in the media, scholarly journals, legislation, and judicial opinions. Many advocacy groups, politicians, scholars, and journalists claim that the country is experiencing a hate crime epidemic. A majority of states have enacted substantive hate crime laws or sentence enhancements for crimes moti- vated by officially disfavored prejudices. A few large police depart- ments have formed bias crime units for investigative and data compila- tion purposes. In 1990, Congress directed the Department of Justice to provide a nationwide accounting of hate crimes. James B. Jacobs is professor of law at New York University School of Law and direc- tor of its Center for Research in Crime and Justice. Kimberly A. Potter is a senior re- search fellow at the Center. The authors thank David Garland for his comments. ? 1997 by The University of Chicago. All rights reserved. 0192-3234/97/0022-0003$02.00 1 James B. Jacobs and Kimberly A. Potter The goals of this essay are to assess the definition of "hate crime," to present what is known about its incidence, and to analyze how the criminal justice system is adapting to this new offense. Because hate crime is a legal construct, and one that varies from jurisdiction to juris- diction, it is necessary to spend a good deal of time with definitions. Only after that groundwork is laid, does it make sense to ask empirical questions. Section I examines the concept of hate crime. Section II sur- veys different types of hate crime laws. Section III examines First Amendment objections to hate crime laws. Section IV presents what is known about the incidence of hate crime offending, emphasizing the difficulties involved in reliable data collection. Section V focuses on a number of different species of offending, offenders, and victims. Sec- tion VI examines the practical problems faced by police and prosecu- tors in investigating and prosecuting hate crime cases. Section VII speculates on the sociopolitical significance of this new category of crime. Section VIII offers a summary and conclusions. I. What Is Hate Crime? The term "hate crime" is a misnomer. The term actually refers to criminal behavior motivated, not by hate, but by prejudice, although there is undoubtedly some overlap. Generically, "hate crime" is meant to distinguish criminal conduct motivated by prejudices from criminal conduct motivated by lust, jealousy, greed, politics, and so forth. Un- like theft, burglary, or assault, hate crime emphasizes the offender's at- titudes, values, and character. Lobbyists for special hate crime laws be- lieve that prejudice is worse than all other criminal motivations (Crocker 1992/93, pp. 491-94). Whereas the classical and the neoclassical models of criminal justice focus on the crime rather than the criminal, the movement to recog- nize and label hate crimes strives to make criminals' motivations salient and determinative. Hate crime laws condemn discrimination by crimi- nals in the same way that Title VII of the Federal Equal Employment Opportunity Act condemns discrimination by public and private em- ployers. For some people, the importance of a hate crime offense category is that it condemns in the moralistic language of the criminal law values and attitudes already condemned via employment, voting rights, and constitutional laws. For others, hate crime laws are important because they punish prejudiced offenders more severely than other offenders who have less abhorrent motivations. Finally, in the context of the 2 Hate Crimes 3 identity politics that characterize contemporary American society (Bernstein 1994; Gitlin 1995), minority groups perceive it to be in their interest to emphasize and even exaggerate their victimization (Epstein 1989, p. 20; Jacobs 1992/93, pp. 542-43; Sykes 1992; Sleeper 1993). At some level of abstraction all crime, or at least a great deal of it, could be said to be motivated by manifest or latent prejudice-against victims because they are tall, short, rich, poor, good-looking, bad- looking, cocky, vulnerable, smart, dumb, members of one gang or an- other, and so forth. In contemporary American society, however, certain prejudices are officially disfavored-especially those based on race and religion. All hate crime laws include prejudice based on race, color, reli- gion, and national origin (Wang 1995, app. B). However, only eighteen states and the District of Columbia include gender or sexual orientation bias as a hate crime trigger. Prejudice against Native Americans, immi- grants, the physically and mentally handicapped, union members, non- union members, right-to-lifers, and those advocating the right to choose are hardly ever included in hate crime laws (Wang 1995, app. B). Some states punish criminal conduct based on uncommon prejudices such as against service in the armed forces (Vermont Stat. Ann. tit. 13, ? 1455) or "involvement in civil rights or human rights activities" (Mont. Code Ann. ?? 45-5-221). The District of Columbia has the most all encompassing hate crime statute; it covers religion, national origin, gender and sexual orientation, "personal appearance," "family responsibility," "marital sta- tus," and "matriculation." Clearly, the boundaries of hate crime legisla- tion are fixed by political decision rather than by any logical or legal ratio- nale. A. The Nature of Prejudice What does it mean to say that criminal conduct is motivated by preju- dice? Prejudice is an extremely complicated concept which has gener- ated substantial social psychological, philosophical, and other scholarly literatures (Allport 1954; Van Til 1959; Gioseffi 1993).1 A simple definition of prejudice is "a negative attitude or opinion about a partic- 1 "Prejudice is not a unitary phenomenon ... it will take varying forms in different individuals. Socially and psychologically, attitudes differ depending upon whether they are the result of deep-seated personality characteristics, sometimes of the pathological nature, of a traumatic experience, or whether they simply represent conformity to an established norm" (International Encyclopedia of the Social Sciences 1968, s.v. "Prejudice," p. 444). James B. Jacobs and Kimberly A. Potter ular group or class of people" (International Encyclopedia of the Social Sci- ences 1968, pp. 439-40). Some commentators would include "irratio- nal" as well. It can result from experience or from fantasies and myths (Ehrlich 1973, p. 15). It can be based partly on fact, or it can be com- pletely fictional. Some people admit to their prejudices, and even es- pouse them as ideologies. Others deny their prejudices, sometimes be- cause they do not recognize them and sometimes because they are ashamed of them. Prejudice can be "subconscious" as well as "con- scious."2 Not infrequently, whether a particular belief or attitude should be labeled as prejudice is a matter on which reasonable people can differ (e.g., Is Z prejudiced if he believes that blacks are more likely to have out-of-wedlock children than whites and Asians and therefore to raise their children less satisfactorily?). There seems to be no agreement on whether "prejudice" includes a negative attitude toward a people which is based in fact (e.g., X does not like or wish to associate with Libyans, because of their govern- ment's sponsorship of international terrorism). Would it be a hate crime if X decided to rob only elderly Asian women because he be- lieved they were likely to resist less than other elderly women? If the definition of prejudice is broad enough, practically everyone could be called prejudiced, or to put the matter differently, practically everyone could be said to hold some prejudiced beliefs and opinions. If so, then every crime in which the perpetrator and victim are members of differ- ent groups could potentially be labeled a hate crime. B. Causality For criminal conduct to constitute a hate crime it must be motivated by prejudice; that is, the criminal conduct must be causally related to the prejudice. How strong must that causal relationship be? Must the criminal conduct have been wholly, primarily, or slightly motivated by the disfavored prejudice? The answer determines how much hate crime there is. If a hate crime must have been wholly motivated by prej- udice, there will be only a very small number of hate crimes-those 2 "Americans share a common historical and cultural heritage in which racism played and still plays a dominant role. Because of this shared experience, we also inevitably share many attitudes and beliefs that attach significance to an individual's race and in- duce negative feelings and opinions about non-whites. To the extent that this cultural belief system has influenced all of us, we are all racists. At the same time, most of us are unaware of our racism.... In other words, a large part of the behavior that produces racial discrimination is influenced by unconscious racial motivation" (Lawrence 1987, p. 322). 4 Hate Crimes 5 perpetrated by individuals whose prejudice amounts to an ideology or perhaps an obsession. By contrast, if a hate crime must have been only in part motivated by prejudice, a significant percentage (possibly nearly all) of intergroup crimes is potentially classifiable as hate crime. What percentage of robberies by black perpetrators against white victims might be classified as hate crime if the key question is whether the robbery or choice of robbery victim was in part attributable to anti- white prejudice? What percentage of violence by males against females ought to be investigated as possible hate crime if the critical question is whether the perpetrator was in part motivated by prejudice against women? II. Types of Hate Crime Laws As of spring 1996, the federal government, thirty-six states, and the District of Columbia have passed hate crime laws that fall into three categories: substantive crimes, sentence enhancements, and reporting statutes. (We exclude antimask and religious vandalism statutes.) A. Substantive Hate Crimes The majority of substantive hate crime statutes are based on the Anti- Defamation League's (ADL) Model Hate Crime Law, which estab- lishes a separate "intimidation" offense: A person commits the crime of intimidation, if, by reason of actual or perceived race, color, religion, national origin or sexual orientation of another individual or group of individuals, he violates Section of the Penal code (insert code provision for criminal trespass, criminal mischief, harassment, menacing, assault and/or other appropriate statutorily proscribed criminal conduct). Intimidation is a misdemeanor/felony (the degree of the criminal liability should be at least one degree more serious than that imposed for commission of the offense). (Anti- Defamation League 1992, p. 4) "Intimidation" is the only prosecutable hate crime under the ADL model law. Thus, in the "ADL states," hate crimes are low-level of- fenses, not the savage violence of organized terror groups but the shoves, pushes, and insults that result from frictions between ordinary, albeit prejudiced people, in a multiethnic, multiracial, multireligious, sexually diverse, and gendered society. James B. Jacobs and Kimberly A. Potter States' hate crime laws differ, not only with respect to which preju- dices transform "ordinary" crime into hate crime, but according to which predicate crimes, when motivated by prejudice, qualify as hate crimes. In Pennsylvania and Vermont, for example, any offense is a hate crime if motivated by race, religion, national origin, and so forth (Pa. Cons. Stat. ? 2710[a]; Vt. Stat. Ann. tit. 13, ? 1455). Other states limit hate crimes to certain predicate offenses when motivated by a dis- favored prejudice. For example, in New Jersey only simple assault and harassment, when motivated by prejudice, are classified as hate crimes (NJ. Stat. Ann. ? 2C:12-1). Illinois designates nine predicate offenses: assault, battery, aggravated assault, misdemeanor theft, criminal tres- pass to residence, misdemeanor criminal damage to property, criminal trespass to vehicle, criminal trespass to real property, and mob action (Ill. Juris. Crim. Law & Proc. ? 61:02). Oregon provides that a person commits intimidation in the second degree, a misdemeanor, when the offender tampers or interferes with property or subjects an individual to alarm by threatening harm to the individual or his or her property or to a member of the individual's family by reason of race, color, religion, national origin, or sexual ori- entation. Where the offender causes physical injury to an individual or his or her property or places an individual in fear of imminent serious physical injury by reason of these characteristics, intimidation becomes a felony (Ore. Rev. Stat. Ann. ? 166.155[1][c]). Most hate crime laws (and sentencing enhancement provisions) do not employ the word "motivation." Instead, they speak of a person who commits an offense "because of' or "by reason of' one of the disfavored prejudices. The Washington, D.C., and Florida laws require that the offense "demonstrate prejudice" (D.C. Code Ann. ? 22-4001; Fla. Stat. Ann. ? 775.085[1]). Some jurisdictions make it an offense (or an aggravating sentencing factor) for a perpetrator to select a victim by reason of race, religion, and so forth (Ore. Rev. Stat. Ann. ? 166.155 [1][c]; Cal. Penal Code ?? 422.6, 422.7), or to "intentionally select" the victim based on race (Wisc. Stat. Ann. ? 939.645[1][b]). Read liter- ally, this type of statute does not even require a showing of prejudice. Consider a defendant who selected his victim, say, an Asian man, be- cause someone who had just seen the defendant's car broken into told him that the thief was an Asian man, so the defendant attacked the only Asian person in sight. The defendant, although not necessarily prejudiced against Asians, would be guilty of a hate crime because he selected the victim "by reason of' race. If the statute is not meant to 6 Hate Crimes 7 cover this situation (which seems likely), then it is no different than a statute that explicitly requires a bias motivation. Professor Lu-in Wang, author of the only legal treatise on hate crime, explains that state courts have uniformly interpreted hate crime statutes to require proof of a prejudiced motive (Wang 1995, chap. 10, pp. 16, 34-35). B. Hate Crime Sentence Enhancement A second genre of hate crime law is comprised of statutes that pro- vide sentence enhancements for prejudice-motivated crimes (Wang 1995, chap. 10, p. 22). These statutes either upgrade an existing offense (e.g., Fla. Stat. Ann. ? 775.085[1]; Wang 1995, chap. 10, p. 11) or in- crease the maximum penalty for offenses motivated by prejudice (Wang 1995, chap. 10, p. 11; NJ. Stat. Ann. ?? 2C:43-7, 2C:44-3). The enhancement may apply to all or just to some predicate crimes. Under the Pennsylvania statute, for example, the bias offender is charged with a crime one degree higher than the predicate offense (Pa. Cons. Stat. ? 2710[a]). Vermont's statute doubles the maximum prison term for bias-motivated crimes; if the maximum term is five years or more, the defendant's bias motivation becomes a factor for consider- ation by the judge at sentencing (Vt. Stat. Ann. tit. 13, ? 1455). In Minnesota, the only bias-motivated crimes subject to enhanced pun- ishment are harassment and stalking (Minn. Stat. Ann. ? 609.749). In contrast, Nevada makes twenty crimes subject to enhanced sentences (Nev. Rev. Stat. Ann ? 207.185). Florida subjects any bias-motivated felony or misdemeanor to enhanced punishment (Fla. Stat. Ann. 775.085[1]). State laws vary with respect to the magnitude of the enhancement for bias motivation. The aggravated battery statute before the Supreme Court in Wisconsin v. Mitchell, 113 S. Ct. 2194 (1993), provided for a two-year maximum prison term, but if the perpetrator was motivated by one of the enumerated prejudices, the maximum punishment soared to seven years. The federal Violent Crime Control and Law Enforcement Act of 1994 (Pub. L. No. 102-322) mandated a revision of the U.S. sentenc- ing guidelines to provide an enhancement for hate crimes of three of- fense levels above the base level for the underlying offense. The guide- line provides: "If the finder of fact at trial or, in the case of a guilty plea,... the court at sentencing determines beyond a reasonable doubt that the defendant intentionally selected any victim or any property as the object of the offense because of the actual or perceived race, color, James B. Jacobs and Kimberly A. Potter religion, national origin, ethnicity, gender [not applicable for sex crimes], disability, or sexual orientation of any person, an additional 3- level enhancement from [the base level offense] will apply" (60 Fed. Reg., May 10, 1995, p. 25,082; emphasis added). In the case of aggravated assault, for example, the ordinary base level offense of 15 is elevated to 18 and the sentencing range is consequently elevated from eighteen- twenty-four months to twenty-seven-thirty-three months imprison- ment. C. Hate Crime Reporting Statutes Many states, as well as the federal government, have enacted hate crime data collection and reporting statutes to generate statistics on the incidence of hate crime (Wang 1995, app. B). Ultimately, these re- porting statutes may have more importance than the substantive laws and sentence enhancement statutes. The old sociological adage "what's counted, counts" suggests that the hate crime reporting statutes will reshape the way that Americans think about crime. The federal Hate Crime Statistics Act of 1990 (HCSA), 28 U.S.C. ? 534 (Supp. IV 1992), mandates the collection of nationwide hate crime data in order to help communities, legislatures, and law enforce- ment personnel appropriately respond to the problem by gathering in- formation on the frequency, location, extent, and patterns of hate crime; increase law enforcement's awareness of and sensitivity to hate crimes in order to improve its response; raise public awareness of the existence of hate crimes; and send a message that the federal govern- ment is concerned about hate crime (U.S. Senate 1989, p. 3). The Act directs the U.S. Department of Justice to collect and report data on hate crimes involving the predicate offenses of murder, non- negligent manslaughter, forcible rape,3 aggravated assault, simple as- sault, intimidation, arson, and destruction, damage, or vandalism of property (28 U.S.C. ? 534 [Supp. IV 1992]). The attorney general, given discretion by the Act to add to or delete from the list of predicate crimes, added robbery, burglary, and motor vehicle theft (Federal Bu- reau of Investigation 1990, p. 4). The HCSA defines a hate crime as "a criminal offense committed against a person or property, which is motivated, in whole or in part, by the offender's bias against a race, religion, ethnic/national origin group, or sexual orientation group." The FBI guidelines implementing 3 The hate crime sentencing guideline is explicitly inapplicable to sex crimes. 8 Hate Crimes 9 the act define "bias" as "a preformed negative opinion or attitude toward a group of persons based on their race, religion, ethnicity/national origin, or sexual orientation" (emphasis added). According to this broad definition, most interracial and other intergroup crimes could be classified as (or certainly be investigated as possible) hate crimes. The guidelines, although quite thorough, leave much ambiguity. For example, what is meant by "ethnic group or national origin"? Are "Hispanics" or "Latinos" counted as one group for purposes of the HCSA? Would an assault by a Cuban against a Colombian count as a hate crime if the assailant was motivated by a belief that Colombians are importing drugs into the community? Are "Asians" (e.g., Syrians, Indians, Vietnamese, Filipinos, Chinese, and Japanese) an ethnic group? Could conflicts between Chinese-Americans and Vietnamese- Americans or between Palestinians and Kuwaitis qualify as hate crimes? III. Hate Speech, Hate Crime, and the First Amendment Defining hate crimes and punishing hate criminals is akin to, but dis- tinct from, the move to criminalize hate speech (Walker 1994; Schweitzer 1995). The anti-hate speech movement asserts that certain kinds of racist, sexist, anti-Semitic, misogynistic, and homophobic ex- pressions and epithets impose emotional damage on persons to whom they are addressed and to other members of the groups to which these persons belong. Therefore, proponents of hate speech restrictions urge that such expressions and epithets be prohibited and that those who utter them be punished (Matsuda 1989; Lawrence 1990). However, hate speech laws have not fared well in the courts, which have declared them unconstitutional on First Amendment grounds (Doe v. University of Michigan, 721 F. Supp. 852 [1989] [declaring unconstitutional cam- pus hate speech code]; UWM Post v. Board of Regents of the University of Wisconsin, 774 F. Supp. 1163 [1991] [declaring unconstitutional cam- pus hate speech code]). There is a lively debate among constitutional lawyers and civil liber- tarians over whether hate crime laws, like hate speech laws, should flunk a First Amendment test (Fleischauer 1990; Gellman 1991, 1992/93; Redish 1992; Gaumer 1994). Those who believe hate crime laws to be constitutional emphasize the familiar speech/conduct distinction in First Amendment law; people are entitled to speak their minds but not to impose physical harm on others in acting out their opinions (Crocker 1992/93, pp. 495-500). They argue that while an individual 10 James B. Jacobs and Kimberly A. Potter has a right to his bigoted thoughts, he has no right to act on them. According to this view, hate crime laws punish antisocial conduct just as Title VII provides a remedy against employment discrimination. Those who believe hate crime laws to be unconstitutional argue that generic criminal law already punishes injurious conduct and that re- criminalization or sentence enhancement for the same offense when it is motivated by prejudice amounts to extra punishment for values, thoughts, and opinions which the government deems abhorrent (Free- man 1992/93; Gellman 1992/93; Goldberger 1992/93). These critics ask: if the purpose of hate crimes is to punish more severely offenders who are motivated by disfavored prejudices, is that not equivalent to punishment for "improper thinking?" For example, suppose there are two defendants: A is a white supremacist who only robs black men; B is a communist who only robs rich people. Under the typical hate crime statute, B would be convicted of robbery, while A would be con- victed of a hate crime or be subject to a sentence enhancement. A few scholars have sought to distinguish between different formula- tions of hate crime offenses (Crocker 1992/93, pp. 495-500; Freeman 1992/93, pp. 582-83). They argue that a hate crime statute that does not use the word "motivation," but that prohibits selection of a victim because of or by reason of the victim's race, religion, or sexual orientation and so forth, has nothing to do with punishing ideas or speech, but punishes conduct. While there may be something to this subtle analyt- ical distinction, most commentators and courts have treated such stat- utes as requiring proof of prejudiced motivation. The U.S. Supreme Court so far has struck down one hate crime stat- ute and approved one. In R.A.V. v. City of St. Paul, 112 S. Ct. 2538 (1992), the Supreme Court was faced with a constitutional challenge to a local ordinance which provided that "whoever places on public or private property a symbol, object, appellation, characterization or graf- fiti, including, but not limited to, a burning cross or Nazi swastika, which one knows or has reasonable grounds to know arouses anger, alarm or resentment in others on the basis of race, color, creed, reli- gion or gender commits disorderly conduct and shall be guilty of a misdemeanor" (112 S. Ct. at 2541). R.A.V., a white juvenile, was con- victed under the ordinance for burning a cross on a black family's lawn. The justices unanimously agreed that the ordinance violated the First Amendment, but there were at least two different rationales.4 Justice 4 The majority opinion was joined by Justices Scalia, Kennedy, Souter, Thomas, and Chief Justice Rehnquist. Justices Blackmun and Stevens filed concurring opinions, in Hate Crimes 11 Scalia's majority opinion pointed out that while the government could criminalize constitutionally unprotected "fighting words" (the ordi- nance applied only to fighting words), it could not criminalize only those fighting words of which the government disapproved. Thus, "the reason why fighting words are categorically excluded from the protec- tion of the First Amendment is not that their content communicates any particular idea, but that their content embodies a particularly in- tolerable . . . mode of expressing whatever idea the speaker wishes to convey. St. Paul has not singled out an especially offensive mode of expression.... Rather, it has proscribed fighting words of whatever manner that communicate messages of racial, gender or religious intol- erance. Selectivity of this sort creates the possibility that the city is seeking to handicap the expression of particular ideas" (112 S. Ct. at 2549). Justice White's concurrence stated that the ordinance could have been struck down simply by holding "that the St. Paul ordinance is fatally overbroad because it criminalizes not only unprotected expres- sion but expression protected by the First Amendment" (i.e., both fighting and nonfighting words [Justice White concurring at 2550]). Therefore, according to Justice White, the majority need not have ad- dressed whether the ordinance affected content-based discrimination. In another concurring opinion, Justice Stevens stated that the ordi- nance did not, as the majority asserted, regulate … Read more Applied Sciences Architecture and Design Biology Business & Finance Chemistry Computer Science Geography Geology Education Engineering English Environmental science Spanish Government History Human Resource Management Information Systems Law Literature Mathematics Nursing Physics Political Science Psychology Reading Science Social Science Home Blog Archive Essay Reviews Contact Copyright © 2019 HomeworkMarket.com .cls-1{fill:none;stroke:#001847;stroke-linecap:square;stroke-miterlimit:10;stroke-width:2px} .cls-1{fill:#dee7ff}.cls-2{fill:#ff7734}.cls-3{fill:#f5a623;stroke:#000}