Hate Biased Crimes in Canada

The purpose of this paper is to explore the depths of the reasoning behind why hate is such a factor in the world.  In viewing the statistics of bias motivated hate crimes, legislation, laws, and policies concerning crimes are having a hard time in evaluating what makes a crime, a hate crime.  These statistics stem from factors related to a crime in which the defendant intentionally selects a victim, or in the case of a property crime, the property that is the object of the crime, because of the actual or perceived race, color, religion, national origin, ethnicity, gender, disability, or sexual orientation of any person (OCRT, 2009).  Hate occurs in every country, any reason to hate seems to be a justifiable reason to do just that.  This paper will explore hate crimes in Canada in an attempt to answer the debate of whether hate crimes are decreasing, or increasing.  For those crimes suspected, as hate motivated, must be defined as such by legislatures, definitions, which must be, applied accordingly (McLean, 2009).

Has there been an increase in hate crimesit depends on which country your asking.  Legislature differs by country in its definition of how a crimes depiction of being that of a hate biased motivated crime.  A pattern to hate crimes relates to the economy, population, and politics.  This paper will review these existing patterns and expand the analysis to other views and levels of aggregation as suggested by the studies.  The rise in hate crimes is suspected however many are unreported as such therefore it is hard statistically to calculate the depth of hate to a varied degree in effecting stricter laws in an effort to decrease these types of crimes.

Thesis
The purpose of this paper is to explore the depths of the reasoning behind why hate is such a factor in the world.  In viewing the statistics of bias motivated hate crimes, legislation, laws, and policies concerning crimes are having a hard time in evaluating what makes a crime, a hate crime.
These statistics stem from factors related to a crime in which the defendant intentionally selects a victim, or in the case of a property crime, the property that is the object of the crime, because of the actual or perceived race, color, religion, national origin, ethnicity, gender, disability, or sexual orientation of any person (OCRT, 2009).

Hate occurs in every country, any reason to hate seems to be a justifiable reason to do just that.  This paper will explore hate crimes in Canada in an attempt to answer the debate of whether hate crimes are decreasing, or increasing.  For the crimes suspected as being hate motivated must be defined as such by legislative definitions, which must be applied accordingly (McLean, 2009).

Introduction
History is a marker of perceived behavior.  It is used by credit bureaus and courts in deciding how a persons past behaviors set the tone for present and future behavior expectations.  It is generally a great tool for correct predictions of such behaviors.  Quantitative research has measured percentiles of hate involving discrimination and prejudice and history has defined that hate is nothing new for society.
Hate crimes have existed for centuries before they ever came to the attention of the judicial system.  From the Roman Empires persecution against the Christians, to Hitlers annihilation of the Jews, to the Genocide in Rwanda, were hate crimes that occurred before hate crimes were criminal acts.

Perpetrators of hate crimes were not all extremists, groups such as skinheads formed to hate without any political views but simply because they hated anyone who was not like them.

In Canada, the realization that there was a problem with hate groups became noticeable in 1965.  It was decided early on that even thought the problem was small at best the potential affect on society could be monumental.  Within 5 years by 1970, the Criminal Code amended to hate crimes as a criminal offense punishable by law, found under Criminal Code, sections 318-320 (Justice Statistics, 1999).
Hate crimes are a new phenomena for Canada, although countries like the United States has conducted much research on this topic.  Racism has been a growing concern igniting hate crimes, which have reached a level of concern for Canada.  This has sparked a need for more research in finding out root causes of why the hate exists, and where it is going.  The results will affect the direction policies are decided, and the course of options available to the legislation (Justice Statistics, 1999).

Canada is taking a stand in understanding the nature of hate and its sudden impact.  They are reviewing statistics in attempts to assess the issues in relation to data collected in pinpointing the objectives of hate groups and those they hate.  Main data gathered depicts victims reporting incidents, which provides insight on the variables of hate crimes and the group associations.  As the hate crimes in Canada began to increase in number and violence, the need for continued legislative changes became evident to keep up with the problem, now deemed one of global impact (Justice Statistics, 1999).

Evaluation of these studies has brought to light reasons of factors that have fueled hate on an individual or group basis leading to hate crimes.  The focus of this paper will be on hate crimes in Canada.  It will look at cases of crimes committed and their impact on victims as well as views of those who committed the crimes.  This writers intent is to unravel reasons associated with causes of why hate is at an all time high.

The hardest hit by hate crimes were Black and Jewish citizens.  Racist views, became racist words, and then racist physical response, with Blacks and Jews at the receiving end of White racism.  The Canadian government is still trying to find out where the hate comes from, why it is so noticeable today and why it grows in intensity.  That would be the question on a global scale.

Statement of Problem
The definitions concerning biased motivation of hate by laws differ per country.  Nizkor (2009) advises the general definition, which is a founding foundation from which countries have generated their own specific understanding, is

A bias-motivated crime is a crime in which the offender is motivated by a characteristic of the victim that identifies the victim as a member of some group towards which the offender feels some animosity.

Now we will look at specific country terminology for bias motivated hate crimes definition by law as depicted by Nizkor (2009) as follows
United Kingdom
The definition used by the police in the United Kingdom is restricted to racially motivated crime incidents, and assumes the following form
(a) Any incident in which it appears to the reporting or investigating officer that the complaint involves an element of racial motivation
(b) Any incident, which involves an allegation of racial motivation made by any person
United States
Definitions of hate crimes vary across the United States. The following examples are representative of these

Hate Crime Any unlawful action designed to frighten, harm, injure, intimidate, or harass an individual, in whole or in part, because of a bias motivation against the actual or perceived race, religion, ethnic background, or sexual orientation of the victim (IACP National Law Enforcement Policy Centre, 1991).

An act, which appears to be motivated, or perceived to be motivated, by the victim based on race, religion, or ethnic background

HateBias Crime Definitions used in Canada
Some police forces provided a clear definition in response to the Department of Justice Canada request for others, the definition quoted below comes from bias crime guidelines provided to officers. The discussion that follows does not include small police forces, several of which have also adopted hate crime policies.

Metropolitan Toronto Police Force
A hate crime is a criminal offence committed against a person or property based solely upon the victims race, religion, nationality, ethnic origin, sexual orientation, gender, or disability.

Halifax Police Department
A hate crime is a criminal offence committed against a person or property, the motive for which is based in whole or in part upon the victims race, religion, nationality, ethnic origin, gender, disability, or sexual orientation.

Edmonton Police Service
Bias crime A criminal offence committed against a person or property that is based solely upon the victims race, religion, nationality, ethnic origin, or sexual characteristic.

Ottawa Police Service
A criminal offence committed against a person or property, which is motivated, by the suspectoffenders hatebias against a racial, religious, ethnic, sexual orientation or disability group.

Winnipeg Police Department
Hate crimes are traditional offenses motivated by an offenders bias resulting of religion, race, nationality, or sexual orientation.  The Winnipeg police service now uses a whole or in part definition of hate crimes. As well, the Hate crime unit investigates incidents of hate crime based on actual or perceived group status.

Montreal Police Force
The Montreal police force uses the same definition used in Toronto (see above).

Ministry of the Solicitor General  Correctional Service of Canada
Crime was motivated because of hatebias toward the victims racial, religious, ethnic, or sexual orientation.

Policing Standards Manual, Province of Ontario
A criminal offence committed against a person or property, motivated by the suspectoffenders hatebias against a racial, religious, ethnic, sexual orientation or disability group.

Ontario Provincial Police
A criminal act against a person(s) or property based solely, or in part, upon the victims race, religion, ethnicity, sexual orientation, or disability.

A bias-motivated crime is a crime in which the offender is motivated by a characteristic of the victim that identifies the victim as a member of some group towards which the offender feels some animosity.  Around the world crimes committed against others in the name of hate continue to occur at alarming rates.  Something must change or we will be a race destined to become extinct by our own hand versus any scientific measure.

To examine hate it is good to look at what the meaning for hate is.  Hate is a word that represents to abhor  things we find repugnant, detest  whatever goes against all we believe in, abominate  things that violate our moral fiber, and loathe  something that makes us feel total disgust (Zimmerman, 2003).  Put all of those together and we have hate.  Hate filled individuals are very dangerous.  They want to eradicate that which makes them feel in such a putrefied manner.

Literature Review
Racism that affects the world is resounding in the election in 2008 of a black man to the office of the White House as President of the United States of America.  There was a surge in crimes against blacks by some whites.  The number of attacks on blacks increased 8 since the election, this accounts for seven out of ten racially charged crimes (Jones, 2009).  Hilary Shelton, director of the NAACP Washington bureau gives advisement that this is the kind of extremism going on.  Obamas election and the recession led to a backlash against blacks as some people look for someone to blame for hard economic times (Jones, 2009).  The election of President Obama sparked hatred long simmering in America by whites, resulting in an increase of hate motivated crimes against blacks (Wallis, 2007).

The NAACP was very familiar with hate crimes enacted against blacks.  The 60s was a volatile period in which the Black Panther Party and the NAACP fought for justice for blacks in provision of equality of rights.  Blacks sought the same equal rights afforded to Whites, but denied to minorities.  Liberty and justice for all was a privilege that was to be for all Americans.  Racism was a key factor for the hate, which was on an extreme level as it was widespread amongst many of the White race.  Justice was slow in coming as those who would serve and protect were some of the biggest haters those of the police force, who enacted police brutality upon black communities.

In retaliation, and to stop the violence of police brutality, the Black Panther Party formed by the Black communities, took on political views in seeking an end to tyranny and the right to quality of life in humanity.  Formed in 1966, the Black Panther Party for Self Defense, founded on the premise of protecting black neighborhoods from being terrorized by police brutality. Police brutality was rampant during those times as police perused the neighborhoods looking for anyone to harass. Black women raped, and black men brutalized.  Justice for these crimes was not forthcoming (Tyner, 2006).

Two men from Oakland, California decided that enough was enough. They formed a committee of people to band together in an organized venture. These men, Bobby Seales, and Huey Newton worked diligently to bring their dream together.   Once a reality, the expansion to seeking equal rights as afforded to whites, became center focus. There were many challenges to face and the manner in which approached did not sit well for all members. There were open disagreements during meetings as members argued against the leaders choices of action (Essence, 1985).

The black panthers represented as a militant group, thought of as political thugs with guns. Whites viewed them as violent and on a mission to eradicate those not oppressed. Whites feared this group of black men blatantly walking around carrying rifles.  The wants of the panthers were simple they desired for all minorities to be afforded the same opportunities for quality in life as whites had. That did not seem like an outlandish request, yet it met with total hate and rejection (Harris, 1968).
Racism was on a global scale as seen through the Panther Parties eyes.  They viewed America as affecting other nations in a negative way.  Further to this, they wanted it made perfectly clear they in no way wanted to connect with a society of a nation built on a bed of lies, rape, and that of being thieves. They emphasized that America may be considered the wealthiest nation in the world, but at the cost of raping all others (Tyner, 2006).

They started several programs for the betterment of blacks. Childrens programs included a free breakfast for children, free medical clinics, self-defense, and first aid. They also initiated an emergency ambulance, drug and alcohol rehabilitation, and sickle cell disease programs. Amidst their lashing out politically, they educated blacks on the ways of politics so they could understand what they were facing and why change had to take place, even if by force.

The black panthers were looking at the future of blacks in a nation that clearly detested blacks and since they were no longer slaves, the nation had turned to using them for a bloody sport. The violence they exhibited was no more heinous than that used on black people, thus the black panthers felt they were righteous in retaliating against violence and defending their right to be human and recognized and accepted as such.

The political views of the party became evident as they advanced their ideals taking them to a higher level. The extremes of complacency that had plagued the black neighborhoods thus inducting them into a state of second-class citizenry had taken its toll. All of the repressed anger had reached a boiling point. The passivity of the past in acceptance of unfair treatment ceased to exist, with the replaced anger reaching volcanic levels erupting forcefully in word and deed.

In stepped Stokely Carmichael to advance blacks into a state of political knowledge and wealth, with nonviolent measures. He led the party in understanding that to be taken seriously in the white mans world when it came to laws was to demonstrate the ability of conducting ones self in a knowledgeable fashion and to let your words be your weapon (Ture, 1997)

Non-violence attitudes met with mixed emotions as the party stood for retaliation and fairness by force if necessary (Tyner, 2996).  The result was a march on the California state capitol in protest of carrying loaded weapons as they felt that it was an attempt by congress to shut down the panther party right to defend themselves. Many violent clashes ensued over time, with many deaths of the party and police force in various raids and other altercations (Palmer, 1969).

Whites continued their victimization on Blacks, and increased their activities during the Black Panther reign. Young men were lynched, women raped, and the brutality continued at alarming rates at the hand of whites in addition to the police force. Many of the brutal incidents went unpunished as the dispute between the panther party and the police, gave the police cause to use it as ammunition against the party (Palmer, 1969).

It was their way of saying look what you have done, your responsible for these attacks on your people.   The parties view was the opposite.  The partys actions further proved why they had a right to claim their citizenry as equals afforded the same opportunities as whites.  They wanted the Black communities to live segregated and left alone to pursue those opportunities without fear of oppression or loss of life and limb this fact was a purpose that they were willing to die for, and many did.

To sum it up about the Black Panther Party, they were a group formed out of the piety of injustice. A group who said, if we arent willing to make sacrifices and take risks, we will never be given the respect that we deserve and will remain in a state of oppression, which paints a bleak future for our children as well as our race. The time is now to stand up and represent that we demand our rights. No more will we wait The time is now to seize the moment. Which is exactly what they did, and their tactics may have been extreme, but none more than the opposition they were facing.

Looking at the NAACP, they worked in a different manner than the Black Panther Party.  Their outlook from the start was to advance and meet Whites on their own terms.  Thus, they were making headway as they became deeply involved with politics.  They had three directives on a mission the same as the Panthers but by peaceful means in order for diplomatic acceptance for change that would be lasting and built off a firm foundation to occur.  They understood if change would have a chance, the attitude of whites in how they viewed blacks would have to change. By this turn of events, they focused their efforts in a political endeavor to reach the masses affording opportunities for whites to see blacks for whom they truly were, and not part of a crippled history that blotted them out as human.

The NAACP set out on a crusade for the civil rights enactment to become a reality in action versus a documentation that carried very little substance. They used the power of the courts to effect the righting of wrongs, and the media to be their voice much in the way of Martin Luther King Jr., on a mission of peace and equality for all people alike.  The objectives of both the Black Panther Party and the NAACP were the same, though the roads on the journey they took differed.

In essence, between the two, a portrayal of blacks as people founded in showing whites the diversity that was as human as their own.  This was in accordance with want, and desire and basic human existence of life.  In other words, it opened the eyes of many whites to the acknowledgment that there was more to these black individuals than met the eye. This alone was enough to spark the attention and support of whites, who were not racially motivated, in assisting with the objectives.

They were accepting to the inviting environment by way of the NAACP and could feel comfortable in assisting to strengthen all people, which would ultimately strengthen the nation. 20 The NAACP was a rock solid civil rights organization on the move. They took the actions of the Black Panther Party and used it to their advantage in demonstrating that hate and violence only begat more hate and violence. Thus, kindness and understanding would begat the same in intent and purpose and was a wise course of action in which to proceed (Rudwick, 1970).

The wisdom of this organization holds true to form, as it continues to thrive and to make monumental differences in the lives of all people. The focus of all people versus the inhumane treatment of a group was a good call in the absorption of freeing the minds of those who would allow the embracing of a people who simply wanted acceptance as such. The work of this organization has provided opportunities to blacks in stopping many of the hate crimes that were so senseless and frequent. They still occur today as the progress in stopping racism is still a continuous battle, but one that is still being fought today, and with each passing decade we get just a bit closer to that accomplishment (Jones, 1970).

Green et al (2001) sociologists with the department of political science at Yale University advise Hate crimes are difficult to measure and explain.  The reasoning behind this is there are too many practical difficulties associated with the collection of data.  The question of why people hate may be answered by the connection to anger itself.  In evaluating why people become angry there are also many unanswered questions.  However, one cannot hate or become violent without becoming angry.  Thus, research invested in the cause and effect of anger on human beings is a start or will assist in finding answers to why people hate and what fuels that hate.

Findings
In the articles explored, courts are having a problem in applying the definition of hate to crimes.  This legislative problem is apparent for all countries, as they define, and redefine the laws in accordance with meeting out punishment specific to a crime committed as defined by law in determining if it is hate related or not.  The pattern of hate is evident per political environment, economic cycles, ignorance at a certain level, and misconceptions.

Discussion
This author has found data on this topic in the forms of articles, books, and websites that show the controversy related to hate motivated crimes affects many.  The mixed reactions to historical reviews associated with how a groups religious, and sexual preferences fuel hate in others, or simply the color of a groups skin, or ethnic capacity brings focus to a problem at times ignored.  That ignorance is now hitting with lethal force, as more persons are becoming targets of hate crimes.

Hate is a powerful tool that denies persons of positive and equal opportunities of citizenry.  It affects quality of life for those who are victims of a hateful system derived from a hateful society.  There has been an increase in reasons for hate, including gender based, and physical.  The apparent patterns once easily viewed have shifted to depict that no particular reason needed to hate.  Hate has evolved to bypassing emotional response of irritation or dislike, jumping forward to hating.  Many questions surface as to the use of labeling.  It is recognized that when a group labels another in a derogative manner, for example, the use of Nigger in reference of the black race (Jones, 2008).

This labeling remained constant throughout history in effect stripping the identity of a race.  As a result, blacks to this day continue in their mission to gain acceptance in a world from which hateful practices have put them in a derogatory light.  Black youth reacting to violence and discrimination, have historically reacted in turn with many growing up to be exactly what white America defined them to be a menace to society.

After the emancipation of blacks from white dominance after the civil war, Whites continued to dominate blacks through acts of racism. These acts include racial slurs, random acts of vandalism, rapes, injustice, violence, and deaths. These issues still exist today after two-hundred years. The hate that whites hold against blacks, held at bay by the laws of the country.  It is smoldering, and waiting to ignite as a fire through hate crimes that some whites enact upon blacks. These hate crimes are increasing in nature, and the question now more than ever is why

Time has evolved, new technology exists in the world, yet, the attitudes of some whites remain rock solid in their hatred of blacks. Research has shown that some whites are very un-accepting of blacks even in todays society (Eberhardt, 2008). The problem is not those who are blatant about their dislike of blacks, but stems more from the whites who subconsciously feel superiority over blacks (Wiese, 2009).

They react in racist ways that they are not aware of, and this is the most damaging. An off colored joke seen as harmless conversations regarding blacks in which whites associate blacks being smart and an asset to their race so to speak as compared to blacks who are viewed as undesirable (Purnell, 2009).
 It is also seen by lower pay standards for blacks, struggles with getting credit, and less opportunities available overall. For every provision of convenience given to a white person, a black must work doubly hard in receiving that same convenience if at all. This is not apparent in daily existence by most, which is why it is so hard to collect the data for research to quantify the unjust treatment (Wallis, 2008).

Hate crimes occur against sexual preference as in Gay rights.  Evidence of homosexuality goes as far back as ancient times. Sigmund Freud expressed his views on homosexuality regarding it as not being an illness but a variation of sexual function because of the cessation of sexual development. He felt that though it would be a desired course of sexuality, one should not be ashamed of it. Freud also felt that persecution of homosexuals was both cruel and an injustice. (Sarason  Sarason, 2005)

In the sixties, the persecution of homosexuals was in full force. America was busy in those days with persecuting the blacks, and women as minorities bashing the gays and dealing with war abroad. It is a wonder that we are still standing as a nation. Concerning homosexuality, people thought that homosexuality was the disease of a mental disorder. No one knew how one went about contracting this disease, but if contracted were assured that it could be treated successfully (Varnell, 1999).

This news in no way calmed their fears, as for every woman who became pregnant,  the normal joy of the proud parents to be in having a healthy baby with ten toes and ten fingers was over shadowed by the realization that the child could be a homosexual. In all actuality during those times, the views of  homosexuals, were the same as those of blacks or perhaps lower than blacks.

In being Caucasian and a homosexual placed whites in a very bad light, as it made the entire Caucasian race look diseased and dirty. The retaliation was to attack the homosexuals in anger and hatred at bringing down the Caucasian race thus, gay bashing was born.  In light of the un-acceptance of their sexual preference and the deadly consequences if found out homosexuals went into a type of seclusion or what was referred to as being in the closet, secluding themselves from their sexual natures and lived life in a depressed state (Varnell, 1999).

Many religious and political issues surfaced about homosexuality with sodomy taking a front seat and driving haters over the edge. Few homosexuals were foolhardy enough to venture out and take the risk of being found out and possibly killed, but for some of those that did they were made an example of by being murdered in the most heinous ways possible, to send a message to other homosexuals that their behavior would not be tolerated (Varnell, 1999).

New accusations cropped up insinuating that homosexuals were sexual deviants who were not to be trusted. It was felt that they would attack any man or boy. Males were more the focus than women were in those times. It was not widely known that women too suffered from this homosexuality disease but gay women made their positions known in the early seventies by starting a feminist movement and boldly labeling themselves as lesbians. (Stein, 1997)

Here we are just three decades later and there have been dramatic changes in how people view homosexuality. In the rise of the Rainbow Coalition, gay men and women have joined ranks in seeking their rights as Americans. Standing up for their individuality and sexual preferences, they want to make it clear that homosexuality is not a mental disorder.

That gay men and women are not socially inept in comparison to heterosexual men and women, but equal by far. The homosexual and lesbian battle for the freedom to choose their sexuality continues. It has progressed to same sex partners being able to adopt children, as research has shown that most children raised in a homosexual or lesbian household, are heterosexuals. Homosexuals and lesbians are now on the brink of being able to get married with the decision from state to state going up and down like a merry go round.

Gays have been targets of hate crimes historically, and gains for acceptance have statistically been more advantageous for this group versus blacks.  Field (2007) speaks on the views of citizenship in Canada regarding the LGBT group in seeking fair practice to the rights of citizenry.  Field brings to focus that laws need changed to view citizenry as a process versus a status.  Her intent is that when a crime is committed in accordance with the factors eliciting that the crime was motivated, and biased by hate, the sentencing shall increase accordingly

718.2 A court that imposes a sentence shall also take into consideration the following principles
(a) A sentence should be increased or reduced to account for any relevant
aggravating or mitigating circumstances relating to the offence of the offender,
and, without limiting the generality of the foregoing,
(i) evidence that the offence was motivated by bias, prejudice or hate based
on race, national or ethnic origin, language, colour, religion, sex, age,
mental or physical disability, sexual orientation, or any other similar
factor, or . . .
(Field, 2007)

The bill C-41 introduced by the Canadian government, in adopting harsher laws in amending the criminal code to fit the crime in association with hate and was viewed as an important step in addressing the problem of targeted violence (Field, 2007).  It fostered hope that the new laws would make it safer for the targeted group as they sought equality in citizenship.

Hate crimes affecting the disabled show assaults enacted upon them for their disability.  Reports show two thirds of 150 people with learning disabilities, who took part in a survey, said they felt unsafe in Barnsley Park after dark, half had been sworn at in the street and 18 had been spat at (Blakemore, 2009).  Canadian policies in legislation are in review for assuring that equal rights given to persons with learning disabilities are fair justice under the law.

Other reports of hate crimes against gender specifically have surfaced with studies focused on the complexities of crimes against women in general as Violence against women is in itself a complex area with its own explanatory framework and is of an essentially different nature to what might be grasped within the notion of a hate crime (Gerber, 2008).  It is now expanding to include violence against women, as the targeting of gender, resulting in new policy creation to deal with this in extending the category to reflect such bias (Gerber, 2008).

Canada has a rich history of discrimination, prejudice, and racism
The colonization of Aboriginal lands by European immigrants was a process that
wove racism into the very fabric of Canadian society. Since then, government and
institutional policies have limited the citizenship rights of Aboriginal people,
people of colour, religious minorities, gays, and lesbians. This is part of
Canadas history of hate. Bigotry against these groups barred them from certain
jobs, voting, receiving public education, buying property and even from entering
Canada.
(WCHD, 2003).

Canada refused to recognize Aboriginal, Chinese, and Japanese descent people as citizens, refusing them the right to vote from the 1870s through the 1940s.   In addition, in 1908, they allowed the rejection of immigrants belonging to any race deemed unsuitable to the climate or requirements of Canada, and in BC, changes to the Public Schools Act in 1908 allowed public schools to reject a child on racial grounds, with the Ontario government allowing segregation of blacks from public schools between 1850 and 1964 (WCHD, 2003).

The efforts of Japanese Canadians included working over forty years in order to be recognized by the federal government to redress the internment and deportation of Japanese Canadian citizens between 1942 and 1949 (WCHD, 2003).

Religious Factors in Hate Crimes
Religion is at the core of many hate crimes.  Whites have expressed from plantation days in following the bible regarding the treatment and enslavement of blacks.  The same holds true for the disdain shown against homosexuals, as many churches are the targets of hate crimes linked to historical value throughout time.

The Catholic Church has suffered a major blow in accordance with the allowance of many gay men to the priesthood in the sixties.  In the sad wake of the continued homosexual abuse of minors of the church throughout the years, Catholicism has decreased as a result.  This was due to many parishes covered up the behaviors and abuse in protection of the priests and the churches sanctity (Kurtz, 2002).

This is a twist of fate as Gays have attacked other religions in retaliation of oppression from God as being against the nature of man and God.  One such attack was on the Mt. Hope Church in Eaton County because it is complicit in the repression of queers in Michigan and beyond (Harris, 2008).  The Gay group picketed with signs bearing the wording of bash back, and using a megaphone, they shouted, Jesus was a homo (Harris, 2008).

Examples of Hate Biased Crimes Committed
Examples of hate biased crimes against LGBT
The death of Aaron Webster, a 41-year-old photographer, was beaten to death on Nov. 17, 2001, in Stanley Park in Vancouver

His death was the result of gay bashing, and resulted in the creation of Bill C-250.  This bill protects the rights of gays.  It includes genocide advocacy, directing hatred against persons of any sexual orientation, heterosexuals, homosexuals, andor bisexuals, is now a crime in Canada. Sexual orientation now joins four other groups protected against hate speech on the basis, of their color, race, religion, or ethnic origin (Cowan, 2005).

Examples of hate biased crimes against blacks
On Election Night 2008, Ralph Nicoletti and Michael Contreras, both 18, and Brian Carranza, 21, of Staten Island, New York decided shortly after learning of Barack Obamas election victory to find African Americans to assault, according to a federal indictment and other court filings. The men then drove to a predominantly African-American neighborhood in Staten Island, where they came upon a 17 year-old African American who was walking home after watching the election at a friends house. One of the defendants yelled Obama Then, the men got out of the car and beat the youth with a metal pipe and a collapsible police baton, injuring his head and legs. The men went on to commit additional assaults that night.

Justin Sigler, 19, of Natchitoches, Louisiana, pleaded guilty in December 2008 to conspiring with two other individuals to violate the civil rights of a man in Lena, Louisiana who was the first African American to move into a home in the neighborhood. Sigler and two others fired shotguns at a target on a field adjacent to the victims property before one member of the group turned his shotgun away from the target and toward the victim and his house. The next evening, Sigler, dressed in a white robe as a member of the Ku Klux Klan, went with his coconspirators to a field adjacent to the victims residence and shouted, White Power and White Knights Shaken by these events, the family eventually sold their home.

Examples of hate biased crimes against women David Edgerly (1998) speaks on the categorizing of crimes against women as hate crimes.

The first scene started in a hot tub near the main pool. Three teenage boys and two teenage girls. Suddenly one of the younger males began to try to yank the swimsuit top off the younger female. She resisted, and he persisted. She resisted further. The male then put a chokehold on the girl and began to pull at the top again as panic clearly swept over her face. The other girl, her older sister, seeing the altercation leapt on top of the male twisted his neck into a grotesquely distorted position and he let go. After a few brief words, all three males left. Neither of the other two males did anything to aid the girl.

Conclusion
In conclusion, the degree of hate biased motivated crimes have afflicted society in reaching debilitating numbers.  Legislation is putting more focus on changing laws and creating new laws to address this problem.  A society is only as good as the people who make it up.  Research is looking into what exact numbers are of a society in relation to those enacting hate crimes versus those not.

Current beliefs are that if we do not stay on top of stricter laws to address this issue there will be more haters than those with an outlook on peace.  Studies to address the political dynamics in relation to economic impacts as well as internal and external processes within judicial settings have provided vital data in the creation of action plans to deter this type of behavior before it has a chance to get out of hand.

Studies have shown that hate crimes occur when a group of persons in agreement of hate filled agendas,  either act against individuals, several persons or more, or groups.  The hate escalates, fueled by others leaving devastation in its path (Anand, 1998).

The controversy goes on in relation to hate crimes around the world.  History continues to repeat itself, and recently the acknowledgment of how hate crimes affect the quality of life, is responsible for new laws in legislation, and the incorporation of action plans with ever changing scopes to keep up with the changing of hate crime agendas.  It appears that those who hate do not really require a bias anymore.  They simply rely on hating for hating.

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