Hate speech is one of the most important conceptual categories in anti‐oppression politics today. A great deal of energy and political will is devoted to identifying, characterizing, contesting, and (sometimes) penalizing hate speech. Though there is no single definition of hate speech accepted by all scholars (Reference LillianLillian 2007, 731), a number of themes commonly appear in this literature. First, hate speech is often described as characteristically hostile. Second, hate speech is thought to do certain things: silence, malign, disparage, humiliate, intimidate, incite violence, discriminate, vilify, degrade, persecute, threaten, and the like. Finally, hate speech is typically understood to be expressive conduct that targets real or imagined group traits. Relevant group traits are commonly taken to include race, religion, sexual orientation, disability, gender status, and (increasingly) gender identity.Footnote ¹ (For an overview of this body of literature, see Reference BrownBrown 2017b.)Footnote ²

It is important to state explicitly that although this language is ostensibly neutral, “race” is nonetheless taken to mean “nonwhite,” “religion” is taken to mean “nonsecular” or “non‐Christian,” “sexual orientation” is taken to mean “nonheterosexual,” and so forth.Footnote ³ In other words, hate speech is taken to express hostility to and about historically and contemporarily oppressed groups, and, in so doing, vilifies, degrades, discriminates, maligns, and so on. It is also important to note that oppression is typically taken to be a condition only of groups, and thus of individuals only insofar as they are targeted for being group members (see Reference FryeFrye 1982; Reference YoungYoung 1990; Reference McGowanMcGowan 2009). That is, no one can oppress Anna qua Anna, but they can oppress Anna qua woman, or qua disabled. The focus on historically and contemporarily oppressed groups, although sometimes implicit due to this ostensibly neutral language, is by no means accidental. It is not simply that the speech in question “picks out” an oppressed group, it is that such speech enacts, and thus reinforces and perpetuates oppression (Reference McGowanMcGowan 2009, 404–405). That is to say, the speech constitutes an oppressive act, and the oppressive function of hate speech is precisely what makes it morally, socially, and politically objectionable.

However, despite the increasing inclusion of gender identity as a socially salient trait, antipatriarchal politics has largely been absent within this body of scholarship.Footnote ⁴ Figuring out how to properly situate patriarchy‐enforcing speech within the category “hate speech” is therefore an important politico‐philosophical project. Since it is quite rare to see detailed analyses of hate speech targeting women, the implication is that hate speech functions in a standard way across these socially salient sites of identity. But, interestingly, Mari Matsuda does not share this opinion. She elects not to analyze gender‐identity hate speech alongside racist hate speech, explaining that this would “require a separate analysis because of the complex and violent nature of gender subordination, and the different way in which sex operates as a locus of oppression” (Reference MatsudaMatsuda 1989, 2332). As I show below, Matsuda is right: separate analyses of hate speech targeting women are necessary. I undertake this task, and in so doing, argue that a certain type of speech that women often encounter—intradivisional misogynistic speech—should be understood as hate speech, despite its targeting only a subset of this oppressed group. I also argue, further, that sexist speech—though oppressive—is not hate speech. This is important since, as Claudia Card explains in another context, recognizing that the concept “hate speech” applies only to certain forms of patriarchy‐enforcing speech is another step in clarifying what is wrong with the practice, and how bad it is in relation to other abuses (Reference Card, Frey and MorrisCard 1991, 297).

This article takes the following structure: on the basis of what hate speech is generally taken to be, involve, and do (as detailed above), I stipulate that hate speech is violently oppressive. Thus, I first review and update Iris Marion Young's “five faces of oppression” and make some grounding remarks. Second, I show that some speech can oppress without the face of violence, and thus—considering that the violent face is a hallmark of expressions considered to be hate speech—that not all oppressive speech is hate speech (though, of course, such oppressive speech remains morally wrong). In the course of this exploration, I show that sexist speech offers a clear example of expression that oppresses without being violent. Misogynistic speech, on the other hand, bears the key characteristics of hate speech (at least some of the time). As such, in section II I explore the difference between sexism and misogyny. Third, I consider the intradivisional quality of misogyny; that is, I show how misogyny divides women among themselves into “good” and “bad” types. Because misogynistic speech most often works intradivisionally, it is unlike most paradigm examples of hate speech that tend to target (for example) racial or religious groups as a whole. Fourth, I go on to consider and dismiss the possibility that women cannot be (or are at least only rarely) the targets of hate speech. I argue instead that an analysis of the intradivisional quality of much misogynistic speech should lead us to a more nuanced understanding of how hate speech functions.

Although some expressions count as hate speech insofar as they target historically and contemporarily oppressed groups, and some expressions count as hate speech insofar as they target a particular individual on the basis of their (perceived or actual) belonging to such a group, so can some speech count as hate speech when it targets a subset of that group. I will argue that intradivisional, hostile, violent speech counts as hate speech when, in practice, it functions to oppress the whole group. This is what misogynistic speech does, and this opens the door for further exploration of other forms of intradivisional, hostile, violent speech targeting subsets of other historically and contemporarily oppressed groups. So, in the final section, I will consider some implications of this analysis and propose some future directions for research. This article contributes to the literature by beginning to fill the lacuna on antipatriarchal politics within this body of scholarship, and by providing a more nuanced account of the kinds of expressions that can and should count as instances of hate speech.

I. The Faces of Oppression

I have said that hate speech is oppressive. However, there are multiple faces of oppression, and in the course of this article I will also argue that not all oppressive speech is hate speech. Thus, to illustrate, it is first important to clarify what oppression involves. I follow Iris Marion Young, who identifies five faces of oppression: exploitation, marginalization, powerlessness, cultural imperialism, and violence. Exploitation involves “the transfer of energies from one group to another to produce unequal distributions” (Reference YoungYoung 1990, 53). Marginalization involves the expulsion of a whole category of people from useful participation in social life (53). Rendering a group powerless involves situating members of that group so that “they must take orders and rarely have the right to give them” (56). Cultural imperialism involves the dominant group “project[ing] [its] own experience as representative of humanity as such,” rendering the dominated group invisible, while paradoxically marking it out by stereotypes (59). Finally, the type of violence that is oppressive must be systematic, targeting persons because of their group status (rather than who they are as individuals, or randomly), and includes physical violence as well as “less severe incidents of harassment, intimidation, or ridicule simply for the purpose of degrading, humiliating, or stigmatizing group members” (61). To these, I would add the face of “subordination,” a characteristically vertical relationship (mentioned by Reference MatsudaMatsuda 1989).Footnote ⁵ Subordination involves rendering a group as lesser or inferior to another on the basis of some (real or imagined) trait or status, without justifiable cause.Footnote ⁶

Why include the face of subordination (as a separate face)? Feminists agree that a patriarchal gender order is oppressive for women. But how is it oppressive? Systemic violence targeting women and girls as a consequence of patriarchal social structures and attitudes is well documented. To offer just one example, consider Card's analysis of rape as a “terrorist institution” (Reference Card, Frey and MorrisCard 1991). Similarly, feminists have argued that men have projected their own experiences as representative of humanity as such, and that our Western culture is accordingly androcentric (see Reference Irigaray and WhitfordIrigaray 1991). Young herself also argues that women are exploited; that

I agree with each of these analyses, but something is missing. Some combination of cultural imperialism and exploitation comes closest to illustrating that women qua group are perceived to be inferior to men and are thus subordinated—indeed, the very perception of women as inferior is likely why men exploit them and why women's perspectives are largely absent from the “representative experiences of humanity.” But it is not clear that every instance of a man subordinating a woman is simultaneously an instance of exploitation—maybe he is not using her for a particular service, but instead patronizing her (without this constituting violence in Young's sense). Similarly, it is not clear that the paradoxical condition of being simultaneously stereotyped and rendered invisible is always (or by necessity) involved in subordination. Some group could be stereotyped not as inferior, but as superior or sacred. And their exclusion from being “humanity's representatives” may occur only because of the perception of this group as separate from and elevated above the “common man.”

I take it that women's simply being perceived and treated as inferior to men (that is, subordinated) is one of the key ways in which women are caged, and that to cage a group on the basis of gender identity (including assumed sex characteristics) is without justifiable cause.Footnote ⁸ That said, other oppressed groups, and not only women, are subordinated on the basis of their (real or imagined) shared traits, too. Thus, the inclusion of this face is appropriate not because it better explains aspects of women's oppression (though it does), but because it better explains oppression generally.

II. Distinguishing between Oppressive Speech and Hate Speech

So far, I have said that hate speech is expression that is characteristically hostile, and that tends to do certain things, like silence, disparage, vilify, degrade, and so forth. I have also said that hate speech targets historically and contemporarily oppressed groups, and that it is a form of oppression itself. Based on the six faces of oppression outlined above, it is clear that hate speech oppresses through violence, which, again, is taken to include less severe incidents of harassment, intimidation, or ridicule and which degrades, humiliates, and stigmatizes group members. A racial slur, for instance, would be oppressive in just this way. However, this does not mean that hate speech is simply violent. Hate speech might simultaneously act as a form of violence and cultural imperialism, or a form of violence, subordination, and exploitation in combination. Take the example of a “whites only” sign hung in a Southern shop front to illustrate this point (Reference McGowanMcGowan 2009, 401): the sign conveys hostility to nonwhites and is an attempt at intimidation for the purposes of degrading and stigmatizing group members, but it is also more than this. It is also an exercise in cultural imperialism and subordination, since it makes out nonwhites to be inferior to whites and treats whiteness as the only truly human identity.

Yet some expressions may be oppressive insofar as they are a form of cultural imperialism and subordination, for example, but fail to include the face of violence. In order to see this, consider the difference between two different types of patriarchy‐enforcing speech: sexist speech and misogynistic speech (and first, allow me to clarify what sexism and misogyny are).

III. Two Forms of Misogyny

What stands out in Manne's analysis of misogyny is that an action need not target all women for it to count as misogynistic. This is unlike sexism, which is interested in maintaining women's total subordination to men. So, as she puts it, “sexist ideology will tend to discriminate between men and women,” whereas “misogyny will typically differentiate between good women and bad ones, and punishes the latter” (Reference ManneManne 2017, 79–80; original emphasis). She observes:

The point is well taken. Of course misogyny is not always universal, since the very purpose of misogyny is to pull women into line with the norms of a patriarchal gender order. Insofar as some (“good”) women are already perceived to be doing just this, it makes no sense to express hostility toward this subset, nor is there a need to coerce their behavior for various ends. Indeed, as Manne queries, “when it comes to the women who are not only dutifully but lovingly catering to his desires, what's to hate, exactly?” (47–48).

That women are divided into “good” and “bad” types is well documented among feminists.Footnote ¹¹ For example, Andrea Dworkin argues that antifeminism, or “the politics of contempt for women as a class,” “breaks down into contempt for particular kinds of women—as men envision the kinds of women there are” (Reference DworkinDworkin 1983, 197, 198). Here, she lists the well‐known tropes of “slut,” “dyke,” and “prude,” among others.Footnote ¹² This is the class of “bad women,” and it coexists with a “woman‐superior” ideological vision where Woman is wholly moral, good, and right. Dworkin explains, “The morally superior nature of women is honored mostly in the abstract. The worship is worship of a symbol—a symbol manipulated to justify the uses to which fallen women are put” (205–206).

Others, including Martha Saxton and Wendy Kline, have demonstrated that variations of this basic ideological split were well entrenched in US culture from its inception as a British colony through to the twentieth century (Reference KlineKline 2001; Reference SaxtonSaxton 2003). Anne Summers has similarly highlighted Australia's ideological division of women into Damned Whores and God's Police (Reference SummersSummers 1994). And this dimorphic vision extends to explanations for (threats of) violence against women, too. In her analysis of rape, Card argues that “rape has two targets: ‘bad girls’ and ‘good girls,’ those who are expendable (‘throw‐away women’) and those to whom a message is sent by way of treatment of the former” (Reference Card, Frey and MorrisCard 1991, 301). That message is: “this is what will happen to you if you are not ‘good,’ if you fail to do as we say” (303). In an analysis of violent language (including threats of rape) targeting women online, Emma Jane further observes that a close look at gendered cyberhate suggests that the already restrictive social categories of “good” and “bad” women “are being further compressed in that all women—even those… who might once have been regarded as God cops—are now being derogated as ‘fucking sluts’” (Reference JaneJane 2016, 28).

We see here another way in which misogyny and sexism are different. On the one hand, sexism is in the business of justifying the subordination of women as a group to men as a group, and it does so by compelling behavior through the deployment of stereotypes and cultural narratives, by naturalizing sex differences, and so forth. Misogyny, on the other hand, is both hostile and coercive, but usually only toward some women, in the service of a patriarchal gender order—namely, to that subset of women deemed “bad.” This makes sense—we would not expect to see hostility or coercion directed at women who are already performing their designated role within patriarchy. However, it would be a mistake to conclude that misogyny according to the “ordinary definition” (that is, the universal hatred of women) never occurs; rather, misogyny takes both interdivisional and intradivisional forms.

IV. Interdivisional and Intradivisional Misogynistic Speech as Hate Speech

The speech I have classified as hate speech is speech that expresses hostility to and about historically and contemporarily oppressed groups, and in so doing vilifies, degrades, discriminates, maligns, disparages, and so forth. Some patriarchy‐enforcing speech—namely, interdivisional misogynistic speech: hostile and coercive speech that targets women as a group—clearly meets these criteria. Interdivisional misogynistic speech may be sexist speech that is in practice transformed into misogyny, or it may be misogynistic speech more in line with the ordinary definition of misogyny as the universal hatred of (all) women. For example, consider the following statements:Footnote ¹³ “I hate women, they're all sluts” (recounted by a twenty‐four‐year‐old white woman, cited in Reference NielsenNielsen 2000, 1055), and “Women never had voting rights [through the] history of man‐kind. And should not have it now either” (Reference JaneJane 2016, 19).

The first example is clearly hostile: what people are really saying when they call a woman a slut “is that she deserves to be fucked as if she's nothing. She deserves to be degraded, violated, and humiliated, because she's worth nothing,” and in this instance, all women are held to deserve such treatment (Reference FordFord 2016, 201). Importantly, this speech is interdivisional: the category “good women” no longer exists; there are only “bad women” and “men.” The second example is more complex, since it could be read either as sexist, or sexist‐cum‐misogynistic. That is, it may be a matter‐of‐fact statement with an implied justificatory component and no air of hostility, or it may be a hostile response to women's political gains through the deployment of sexist reasoning that is intended to coerce women's compliance. The context suggests that the latter interpretation is appropriate, since it is preceded by the statement “All feminists should be gang raped to set them right. Plus work in a [w]hore house for a year or so” (Reference JaneJane 2016, 12). Here we see the slippery transition from the hostile intradivision of women, to interdivision between women and men. In both examples, the coercive factor is in play in an attempt to silence women and to shut them down, whether by shaming them or making them feel threatened.

It is (hopefully) uncontroversial to classify these speech acts as hate speech. But as we have seen, this is not the most common form of misogynistic speech that women face. Women are far more likely to be subjected to misogynistic speech that is intradivisional, and hence that does not target the group “women” as a whole. The “all feminists should be gang raped” comment is an instance of intradivisional misogynistic speech intended to coerce “bad” women: to shut them down, shut them up, and get them to shape up. Consider some others (the violence of which is obvious): “You know the best thing about feminists is they don't get any action so when you rape them it feels 100 times tighter,” and “[You're] fucking basic sluts who couldn't get pipe even from their plumber” (in Reference ChalmersChalmers 2015).Footnote ¹⁴ The comments are clearly hostile: they aim to scare and shame “bad women.” The first implies that a woman ought not to be a feminist (that is, against patriarchy), as feminists are ideal rape candidates. (Manne points out that the natural targets of misogyny will be feminists, because it is this category of women who push back hardest against patriarchal norms—see Reference ManneManne 2017, 51.) The second attempts to silence “bad women” by suggesting (paradoxically) both that their sexual activity is exaggerated and hence they are unworthy of respect, and that they are incapable of engaging in sexual activity as no man desires them; hence, they are of no value. They are clearly coercive, too: as with the above example, they aim to shut “bad women” up and prevent future similar resistance.

How should we classify this speech, speech that targets only a subset of a group, rather than a group in toto? Perhaps much misogynistic speech is not hate speech after all? Perhaps there is something particular about the nature of gender‐identity oppression that makes it unlike other forms of oppression (such as racial oppression, sexual‐orientation oppression, and so forth)? This is not a totally preposterous idea, and many scholars have gestured toward this peculiarity of “women's condition.” For example, Catharine MacKinnon comments that “substantively considered, the situation of women is not really like anything else. Its specificity is not just the result of our numbers… and our diversity, which has at times obscured that we are a group with an interest at all” (Reference MacKinnonMacKinnon 1987, 166–67; original emphasis). She thinks women, unlike other groups, have a status as a group relative to men. Likewise, Simone de Beauvoir points out that women “live dispersed among men, tied by homes, work, economic interests and social conditions to certain men—fathers or husbands—more closely than to other women” (Reference BeauvoirBeauvoir 2009, 8–9). Finally, unlike other oppressed groups, men do not aim at the total eradication of women (Reference LillianLillian 2007, 732; Reference Weston‐ScheuberWeston-Scheuber 2012, 145).

Perhaps women's oppression is quite unlike that of other groups. So, perhaps they cannot be victims of hate speech, or, if they can, perhaps this is quite rare. Manne considers this challenge with regard to her ameliorative project on misogyny more generally. The assumed requirement of universality is founded, she believes, on an unwarranted assumption that “misogyny must resemble the most commonly… envisaged form of anti‐Semitism, which is supposed to be leveled at the entire Jewish people in our entirety” (Reference ManneManne 2017, 52). Yet, she responds, “why should this one type of oppression be treated as the paradigm?… Gender‐based oppression may be partly sui generis” (53). I agree with her on this point: the onus is on those who require universality, particularly given the variety of faces with which oppression can present, to show why this is the case. However, while gender‐identity oppression may be partly sui generis, we need not rush to this conclusion, as further reflection on hate speech and misogynistic speech shows.

Even if we accept that the group “women” is quite different from other oppressed groups, I nonetheless believe that intradivisional speech ought to be classified as hate speech. Here is why: although it is not immediately obvious, intradivisional misogynistic expressions do, in fact, oppress the whole group. As Kylie Weston‐Scheuber explains, on the surface, “women are not considered to be ‘interchangeable’ by society in the same way as victims of racially or ethnically motivated crime,” and this is why a “harm committed against an individual woman is not considered to impact on other women in the same way that [a] crime committed against a member of an ethnic group might be seen as a harm to all members of that group” (Reference Weston‐ScheuberWeston-Scheuber 2012, 142). However, this assumption simply obscures the fact that women are used as “stand‐ins” for one another with frequency (Reference ManneManne 2017, 54). Furthermore, women who read or hear intradivisional misogynistic messages “understand that they could be the ‘next victim’ and that the last victim was targeted because she was a woman” (Reference Weston‐ScheuberWeston-Scheuber 2012, 142; original emphasis). Thus, it does not matter that only some women—“bad women”—are targeted with intradivisional misogynistic speech. What matters is that all women know they are liable to become targets simply because they are women, and thus the violence and hostility has total impact. No matter how hard a woman tries to be “good,” she is always at risk of being perceived as “bad” by some man (or woman). Thus, intradivisional misogynistic speech has “the power to prescribe and enforce a social reality that is morally unjust” for all women (Reference Tirrell and CardTirrell 1999, 238).

Moreover, it is not clear that hate speech toward other marginalized groups is (always) part of a system that aims at universal eradication, so it is not even clear whether patriarchal oppression really is partly sui generis (though it may be). As Donna Lillian points out, “even in the 21st century, African Americans and Latinos/as are not the targets of mass genocide because capitalism demands that there be an exploited underclass without which capitalism would collapse” (Reference LillianLillian 2007, 732–33). That is to say, there are potentially many oppressive ideologies that may require the oppression and continued existence of a particular group. Relatedly, it seems as though other paradigm “protected” groups are targeted with intradivisional hostility too, so it will be beneficial for anti‐oppression politics to develop a more robust and nuanced understanding of hate speech so as to capture such expressions quite generally. For instance, consider Donald Trump's statement about Mexican immigrants: “They're bringing drugs. They're bringing crime. They're rapists. And some, I assume, are good people” (in Reference ReillyReilly 2016). Clearly, it is not only gender‐identity groups that can be classified into “good” and “bad” types. Speech acts of this kind also appear to work through hostility and systemic violence to oppress Latino/as within the US context quite generally, and do not seem to aim at universal eradication. It seems to me quite right that this be classed as an instance of hate speech, although it does not technically target an entire racial group.

V. Implications and Future Directions

In this article I started from the observation that hate speech is characteristically hostile, that it targets historically and contemporarily oppressed groups, and, in so doing, does certain things. Namely, it (further) oppresses through systemic violence, and may degrade and/or silence, vilify, discriminate, and so on. I have also observed that there are several faces of oppression, of which violence is only one. Finally, I pointed out that anti‐patriarchal politics has largely been ignored within scholarship on hate speech. Given that hate speech is one of the most important conceptual categories in anti‐oppression politics today, and that a great deal of energy and political will is devoted to identifying, characterizing, contesting, and (sometimes) penalizing hate speech, figuring out how to properly situate patriarchy‐enforcing speech within this category is an important politico‐philosophical project.Footnote ¹⁵

I analyzed two kinds of patriarchy‐enforcing speech, sexist speech and misogynistic speech. I argued that sexist speech is oppressive, and considered examples that illustrate the exploitative, imperialistic, and subordinating aspects therein. But because these are not systematically violent, they do not oppress in the same way as hate speech. They also do not convey hostility, nor do they coerce behavior—although it bears stating that sexist speech may do some of the same things that hate speech can do (for example, silence those to whom the speech is directed). Thus, I argued that sexist speech, while oppressive, should not be understood as hate speech. Misogynistic speech, on the other hand, at least in its interdivisional form, appears to illustrate all the hallmark traits of hate speech. It targets a historically and contemporarily oppressed group, is characteristically hostile, systematically violent, and degrades, stigmatizes, vilifies, and disparages its targets (among other things).

However, interdivisional misogynistic speech is relatively rare. Misogynistic speech usually targets only subsets of women—that is, it is usually intradivisional. This makes most misogynistic speech seem unlike paradigm examples of hate speech, which tend to target groups holistically. But I argued that instead of reaching the conclusion that women are simply infrequent targets of hate speech, or cannot be targets at all, we should consider intradivisional misogynistic speech as hate speech, too. We grant that intradivisional misogynistic speech is hostile. We also grant that women are targeted with such speech because they are women: women in a man's world who are held to be failing to live up to patriarchal standards. This explicit intradivisional misogynistic speech also vilifies women by employing stereotypes and bias. It displays attitudes of women's general inferiority to men, in spite of targeting only a certain subset of women. That is to say, not only is this speech violent, it is also subordinating and imperialistic, tending toward exploitation.

This is evident, as intradivisional speech is used against women quite generally, in all sorts of settings, including when there can be no perception of a woman's character or her history (Reference Weston‐ScheuberWeston-Scheuber 2012, 145). It is precisely this observation that led Jane to comment that “even those who might once have been regarded as God cops are now being derogated as fucking sluts” (above). This is also echoed by Dworkin when she suggests the model of the “good woman” is in fact a ruse employed by men to ensure the compliance of all women with patriarchal norms. Intradivisional misogynistic speech does degrade, dehumanize, and debase the entire group “women,” even as it subdivides it, since even “good women” are still not worthy to be esteemed and recognized as equivalent to men within a patriarchal gender order. So, we have in fact learned something about the way hate speech functions: we know that groups are oppressed in the first instance, and that individuals are oppressed only insofar as they are group members, but we have also learned that hate speech attacks not only individuals as members of groups, but also subsets of those groups (for example “feminists,” “sluts,” and so on) in order to keep the entire group down. This is true of misogynistic speech, and likely of intradivisional speech targeting other groups too (though perhaps this is far less common).

All of this has foreseeable social consequences and implications for future research. For instance, those countries that have laws prohibiting hate speech, but do not recognize gender identity as a ground upon which to lodge a claim, will need to amend those laws. In Australia, this would require amending legislation in all states other than Tasmania (where it is recognized as a civil offense), as well as federally, to give just one example (Reference Weston‐ScheuberWeston-Scheuber 2012, 138). But the jury is still out as to whether legal prohibition is the best course of action for dealing with the harm(s) of hate speech. Still, this does draw out other interesting questions. For instance, how should we address oppressive speech, such as sexist speech, which is not “hate speech”? Would there be more or less warrant for legal intervention in these cases? There are other important questions too: just how common is it for other subsets of groups to be targeted with intradivisional hostile violent speech as a means of keeping the entire class down? Another question: are there (for instance) some forms of racist speech that have been mischaracterized as hate speech in the literature, failing to display the relevant face of oppression or to display hostility? And what of more covert hostile expressions whose violent face is veiled—how do we reveal the violence implicit in such speech, and have these expressions taken seriously as one of the ways oppression is both sustained and perpetuated? The social, political, and legal implications of this refined account of hate speech are of urgent importance in understanding women's oppression and the oppression of others.