Yeah lets take a look at the two countries. Which one is more Fascist.
All of this in just 43 years......what rights will you lose in the next 40 years?
Freedom of expression
While both nations protect freedom of expression, Canada's guarantee is explicitly subject to "reasonable limits" and does not extend to the same degree as in the U.S..ย
Reasonable Limits Clause: Unlike the U.S. First Amendment, the Canadian Charter of Rights and Freedoms includes Section 1, which permits the government to restrict rights if the limits are "demonstrably justified in a free and democratic society".
Hate speech laws: This clause allows Canada to prohibit and prosecute hate speech, something the U.S. Supreme Court has generally ruled is protected speech.
Legislative override: A "notwithstanding clause" in the Canadian Charter also allows a provincial or federal government to override certain rights, including freedom of expression, for up to five years
Gun ownership
In Canada, gun ownership is considered a regulated privilege, not a constitutional right like in the U.S..ย
No right to bear arms: Canada has no equivalent to the Second Amendment. This allows for significantly stricter federal gun control measures, including mandatory training, licensing, and background checks for all gun owners.
Permit restrictions: Permits for handguns are highly restricted, often limited to collectors and gun club members, and carrying a firearm in public is illegal in most circumstances.
Assault weapons bans: Canada has also banned nearly 2000 types of assault-style firearms, a restriction that is politically and legally challenging to enact in the U.S
Property rights
Unlike the U.S. Constitution, the Canadian Charter of Rights and Freedoms does not include a right to property.ย
No constitutional protection: The absence of a constitutional property right can provide less legal recourse for Canadians in disputes involving the state, though property rights are protected through common law and statutes
Right to counsel
While suspects in both countries have a right to legal counsel, the U.S. system provides stronger protections during police interrogation.ย
Interrogation rules: In the U.S., the Miranda rights mean a suspect can request an attorney be present during questioning, and police must stop questioning. In Canada, an adult suspect only has the right to consult with a lawyer, not to have one present during the interrogation.
Confession admissibility: The differences in these rules have led to concerns among Canadian legal experts that the country's system can pressure suspects into false confessions
The notwithstanding clause
Canada's Constitution contains a provision that allows federal or provincial governments to temporarily override certain Charter rights.
Canada: The "notwithstanding clause" (Section 33) allows a government to pass a law that operates despite its conflict with certain Charter rights, such as fundamental freedoms or equality rights. The law must be explicitly stated to operate notwithstanding the Charter and is temporary, expiring after five years unless renewed.
United States: The U.S. Constitution has no similar provision. Once the Supreme Court rules a law unconstitutional, it is struck down
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