penalty enhancing statues: Wis. v. Mitchell 9-0
i) okay b/c we are punishing criminal conduct, not speech & not for abstract beliefs
ii) but gov’t may not introduce evidence of affiliation w/ hate group (KKK) in a criminal trial b/c unrelated to crime & violates freedom of ass’n (Dawson v. Delaware)
iii) still must have a direct causal connection between the motivation (beliefs) and the crime
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