you're spot on that scope matters. ze german laws about āhateā memes are baked right into the federal criminal code (§§ 86, 86a, 130 stgb), so every cop and prosecutor has to play alongāa top-down blanket ban.
in the u.s. case itās still technically unconstitutional, but that doesnāt stop local cops from arrest-first-ask-later. when you end up sitting in county for 37 days over a shitpost, āisolated incidentā kinda loses its soothing effect. the chilling vibe spreads either way.
point is: whether itās system-wide lawfare or a rogue department violating the law, the net result for the meme lord looks the same: cage time.