context: Minnesota is not unique in using "because of' in its formulation of bias assault; other courts have interpreted the same words in similar statutes to require the state to prove a causal connection between the infliction of injury and the assailant's perception of the group to which the victim belongs. By requiring a causal link, the statutes exclude offenses committed by a person who entertains racial or other bias but whose bias is not in substantial part what motivated the offense.
citation_a.signal: cf.
citation_a.identifier: 505 U.S. 377, 391
citation_a.parenthetical: finding ordinance aimed exclusively at speech to be impermissible, content-based discrimination
citation_a.sentence: Id., 42 Cal.Rptr.2d at 367-68, 896 P.2d at 1377; Plowman, 838 P.2d at 563; see also Mitchell, 508 U.S. at 487-89, 113 S.Ct. at 2201 (racist speech may be introduced to prove motive for conduct unprotected by First Amendment); cf. R.A.V. v. St. Paul, 505 U.S. 377, 391, 112 S.Ct. 2538, 2547, 120 L.Ed.2d 305, 323 (1992) (finding ordinance aimed exclusively at speech to be impermissible, content-based discrimination).
citation_b.signal: see also
citation_b.identifier: 508 U.S. 487, 487-89
citation_b.parenthetical: racist speech may be introduced to prove motive for conduct unprotected by First Amendment
citation_b.sentence: Id., 42 Cal.Rptr.2d at 367-68, 896 P.2d at 1377; Plowman, 838 P.2d at 563; see also Mitchell, 508 U.S. at 487-89, 113 S.Ct. at 2201 (racist speech may be introduced to prove motive for conduct unprotected by First Amendment); cf. R.A.V. v. St. Paul, 505 U.S. 377, 391, 112 S.Ct. 2538, 2547, 120 L.Ed.2d 305, 323 (1992) (finding ordinance aimed exclusively at speech to be impermissible, content-based discrimination).