Judah Grunstein is editor-in-chief of World Politics Review. He has lived in Paris for seven years and in France for 14.

PARIS—Not long ago, I stood on the bus before two seated Catholic nuns, both wearing the veils and robes of their order. For months I’d been hearing friends, acquaintances and strangers complain about the increasing amount of Muslim women wearing the veil here. And somehow, upon seeing the nuns, the thought instantly formed in my head, a silent, ironic reply to the increasingly audible Islamophobia here in France: “I’m getting so tired of all these veiled Muslim women!”

The episode was followed soon thereafter by another, similar in theme but this one more unsettling. As I was exiting the Tuileries garden on my morning run, I found myself behind a woman wearing a veil covering her head and neck. (From behind I could not tell anything about her features, but steps later I would confirm she was of Maghrebin origin.) An older woman approaching from the opposite direction—a “ français de souche,” as French people say of anyone whose ancestors immigrated here more than 200 years ago—looked her up and down unsympathetically.


“Don’t you look like an idiot!” she spat as she passed.

I was too taken aback, and somewhat out of breath, to say anything on the spot. But steps later, l’esprit de l’escalier formed another fitting reply in my head: “Would you say that to a nun?”

Both responses are the kind of caustic humor that Charlie Hebdo used against anyone who believes too sanctimoniously in their own monopoly on the truth. Ideally the goal is to remove people’s blinders, but more often than not the effect, for the benighted target of the joke, is closer to a poke in the eye. Yet whereas I kept my acerbic thoughts to myself, the editorial team at Charlie Hebdo published theirs, and continued to do so regardless of the threat of violence they knew they lived under.

I thought of both episodes in the aftermath of the attack on Charlie Hebdo’s offices Wednesday, which was almost universally interpreted as an attack on the very principles of free speech and a free press. Though that is the correct interpretation, the very different meaning of those principles on either side of the Atlantic is likely to come into sharper focus as the shock of the attack begins to wear off.

Both France and America make the sanctity of free speech a core principle. But at various times over the past 14 years that I have lived here in France, I have been called on by my American friends to “translate” just what the French mean by “free speech.” In particular, they have been perplexed by the willingness to place limits on speech and, relatedly, religious expression here. This first became visible in the context of the law against wearing veils in public schools and government buildings. More recently, it arose when the government banned the one-man show of the ostensible comic Dieudonné, due to offensive jokes about the Holocaust and gas chambers. Put simply, in France, racist and anti-Semitic speech, as well as historical revisionism regarding the Holocaust, is illegal, as is all speech that can be considered an incitement to hate. That is something that very few Americans understand—or approve of.

That approach is at times contested here in France, too, due to what some see as selective enforcement of the law. The case of Dieudonné, for instance, has become something of a cause célèbre among fringe groups as proof of a double standard. French authorities officially shut down his show last year as a menace to public order. But the fact that he was subsequently allowed to stage a largely identical show purged of the offending routines left little doubt among his supporters—a diverse mix of second- and third-generation Arab-origin French people, 30-something far-right former skinheads and older left-wing intellectuals—that he had been officially censored. They argue that Diedonné’s jokes about the gas chambers are the same kind of insensitive speech that Charlie Hebdo made a vocation of directing at Muslims (if also Jews and Christians).

While Charlie Hebdo was sued for racism over the re-publication of the Mohammed cartoons, it was acquitted, with the broad spectrum of the French political elite expressing their support for the principle of satire. Dieudonné, by contrast, has been convicted six times for various anti-Semitic slurs. The difference in treatment, his supporters claim, is proof that when it comes to offensive humor, Muslims are fair game, but Jews are off-limits.

All of this is worrisome for the nation's future. France does have a long tradition of freewheeling, iconoclastic, equal-opportunity offensive humor, in which Charlie Hebdo, and at other times in the country’s history Dieudonné, fit in seamlessly. But in the current climate of social unraveling, there is something unsettling about the way this tradition is manifesting itself today. A recent French comedy—“ Qu’est-ce qu’on a fait au bon Dieu?”—dealt with an older couple of “ français de souche” and their anguish over their three daughters’ interreligious marriages, and their fourth daughter’s interracial one. (Overjoyed to learn their youngest is marrying a Catholic, they are crestfallen to find out he is black.) The movie was a major success, but it caused some soul-searching for its use of over-the-top racist jokes and stereotypes. Its clear message was to suggest a kind of truce: Everyone’s a racist, even racial minorities, so let’s just all get along instead of hating each other for our differences.

Nevertheless, many worried that the movie’s brand of politically incorrect humor would "loosen tongues" at a time when the far right is already making inroads into traditionally leftist demographics that have historically been bulwarks of the social justice movement. My experience in the Tuileries suggests there is something to that concern.

Meanwhile, Charlie Hebdo is being embraced by American commentators as a champion of free speech and press freedom. Certainly this is true, and the courage it took to not back down in the face of threats of violence is admirable and humbling. But the editorial staff was also something of an old boys' club whose brand of leftist, anti-clerical, at times misogynist humor would probably make some of their pious Stateside defenders a bit uneasy were they actually to see more of it. If it were a campus publication, chances are it would be shut down for religious and gender insensitivity. And while it would be free to operate in the private sector, it would almost certainly be targeted for a boycott campaign by any number of American commentators, progressive and conservative alike, currently championing it. This speaks to something of a paradox in Americans’ approach to free speech, and not just with regard to the proliferation of campus speech codes and hate crime laws: There are no legal means to keep someone from speaking their mind, but the law is not the only method of silencing someone.

Clearly there is a huge difference between boycotting a publication and banning it—to say nothing of killing off its editorial staff. But with regard to the deeper questions this raises about principles of free speech in both France and America, there are no easy answers, especially when it comes to the proper balance between self-expression and self-restraint.