A Comparison of
The United States and Turkey

World Fact Book on Turkey

An overview of United States law on censorship

While censorship laws in the United States are certainly stricter than those of most other countries, the right to free speech is still a very powerful one. This law gives people the right to speak their beliefs, with certain restrictions. As long as there are no threats or plainly vulgar language, the government allows people to publish things that are against the government or other groups of people, and to show this type of information on television. Unfortunately, determining what is protected under freedom of speech and what isnít becomes open to interpretation by the courts.

Censorship in the US also limits the amount of violence and sex that can be printed or shown on television. The United States censors all nudity and sex from public television, and puts age requirements on printed materials of this nature. On the other hand, the laws governing violence in media is much less strict. Very few violent shows or movies are restricted from television. Foreign people often find this to be a little backwards since most countries in the world will show nudity before violence.

Laws governing acceptable Internet use are fairly new and not well refined. Most censorship laws about the Internet are very similar to those pertaining to printed media. Pornography is allowed, assuming age restrictions are put in place. The only pornography specifically banned is child porn. People have the right to say what they want in emails or on their web pages, so long as it is not threatening or harassing. Again, many of these laws are still being written and refined, and are often still open to a lot of interpretation as to what classifies as threatening or harassing.


Situation A: There is an American hosted web site is publishing material that is sympathetic to a Montana based 'militia'.

Government Action: None, unless the web-site is actively promoting terrorism against people or the government.

Situation B: There is an American hosted web site is publishing material that is calling for a complete overhaul of the government.

Government Action: None

Situation C: There is an American hosted web site is publishing material that is calling for public support for the national communist party.

Government Action: None


An overview of Turkish law on censorship

Current laws in Turkey laws are very complicated. For the most part though they are very similar to the laws in the United States. Just like in the United States it is a question of what is enforced.

One of the laws that United States was founded on, is also major law in Turkey, The Freedom of Speech, it exists in Turkey, but the speech must be in acceptable bounds. The speech is considered unacceptable if it is used to start an anti-government movement or is a terrorist speech. Several newspapers and TV stations get shutdown for short times for using unacceptable speech.

There are no laws in Turkey on violence and nudity on the Internet, TV and the movies. Movies have some restrictions. Some movies you have to be 18 to see. It is not enforced, though. There are no laws in Turkey on subject of dress. Nudity is allowed on TV and newspaper commercials. This is true of nudity for most part of Europe. Nudity is a less sensitive subject than violence in Turkey.

The Internet has made a fast impact on the world, but even a quicker impact on Turkey's society. There has been little time for Turkey to set laws on the use of the Internet. So, things such as porn and mp3's are not legal. Copyright laws are not yet enforced in Turkey, yet. Companies are just now starting to follow these copyright laws. Pirated software is a big industry in Turkey.


Situation A: There is a Turkish hosted web site is publishing material that is sympathetic to the Kurdish 'freedom fighters'.

Government Action: The web site is would be shut down under a law that prohibits the distribution (through radio, TV or print) of material that may cause the people to hate the government. This law is rarely enforced, but would be used in this situation because the subject (the Kurdish 'freedom fighters') are generally in poor favor with the general population.

Situation B: There is a Turkish hosted web site is publishing material that calls for a complete overhaul of the government.

Government action: None

Situation C: There is a Turkish hosted web site is publishing material that is calling for public support for the national communist party.

Government Action: If at all, the action would consist of the web site being shut down officially but it would probably re-appear in a few days under a different name, with very close (if not exactly) the same content. The communists are not in such poor favor with the Turkish population, therefore, the reappearance of the web site would be overlooked for a while before it is shut down again. Like shampoo instructions, repeat as desired.

Key Differences between United States law and Turkish law on Censorship

In many ways, the censorship laws of these two countries are quite similar. Turks too have a freedom of speech, and are allowed to print or air on television almost anything. Limits to this include terrorist activity, or threatening and harassing media, much like the United States. One major difference in the two countries is the punishment for abusing freedom of speech. Very often in the US, if someone violates censorship laws, they are fined or thrown in prison. In Turkey, a television station that breaks these laws is shut down for a matter of days only, and is then allowed to resume normal operation. The United States has a much stiffer penalty for violation of censorship laws.

One area where the two countries differ greatly is censorship of nudity and sex on television. In the US, almost no nudity, sex, or vulgar language is tolerated. In Turkey, full frontal nudity is allowed on television, even in advertisements. Sex is also allowed, as long as it is not graphic hardcore pornography. This is one area where the United States differs from most of Europe.

Laws governing the Internet in Turkey are again similar to those in the United States. Very few laws are in place in either country. Pornography on the Internet in Turkey has little or no restrictions governing it. While this is currently true in the US also, many people are looking to change it.

Overall, we found that most censorship laws are quite similar in these two countries. The main difference is the permission of nudity on television in Turkey, and the violence allowed in the United States.

The Positive and Negative Aspects of the Law and the Peopleís Opinion

Although it is obvious that the laws in Turkey and the United States are very different, one aspect of society that we havenít discussed is how the citizens of each country view these laws. The laws in Turkey seem much looser concerning the censoring of violence and sexual content than do those here in the United States. It seems that nudity, in general is more accepted by the citizens of Turkey. Quite a great deal of debating has been done here in the United States concerning this issue as this country tends more to the conservative side of this issue. However, in contrast, the United States citizens seem to be equally concerned, if not more so, with censoring violence on television in comparison to sexually explicit material. In Turkey, violence, especially on television, does not create the uproarious reaction it does here in the United States. Turkish citizens, though not over-concerned with the existence of sexually explicit material, are more concerned about regulating it than they are about regulating the expression of violence. Some of this could be the contrast in the social and moral backgrounds of the two nations. While the United States is predominantly Christian, Turkey, as our interviewee informed us, is mostly Muslim. This fact influences much of how they view these different issues.

Another issue was government censorship of the television networks. Though the two networksóstate and privateóexist, the government does censor the content to a certain degree. If the television station in question aired material criticizing the current government or something that was extremely controversial, it reserves the right to keep the station from broadcasting for a certain length of timeóa very muted sense of censorship. Our interviewee did not seem to think this was a great hardship. Evidently it happens only on occasion and citizens take the inconvenience in stride.


The biggest difference is that the Turkish government has the means to silence any group that it feels it is in opposition with by saying that the group has been contributing to a growing negative attitude of the people towards the government. However, this law is rarely employed, and is done so only when the vast majority of the population concurs with action, as is the case with the Kurdish 'freedom fighters'. The fact that this law is still on the books might be considered a threat to free speech, but there have been several movements to take this law off the books. All such movements have failed to this point, but it is expected to pass in the next 5-10 years.

Key Differences between the Three Situations

With situation A, it is possibly the best outcome that a real treat to government should be silenced, 9 times out of 10. Sometimes when a few crazy people can take a radical point of view, then they could potentially draw in other only to brain wash them thus creating real havoc when they decide to act. The Turkish government seems to only apply this law when there is a real treat. As we see it the only problem with the Turkish system is that if the government would really go corrupt then the government could defend itself from a revolution that is really necessary. So in the end as it is now, in the united states the militia movement is not really a problem and one of the greatest American ideals is the over through of a potentially corrupt government. So as Americans we would have to side with the American system because of our ideals.

With situation B, the outcomes are the are exactly the same so for the purposes of picking which side has the best outcome we are going to go with both the American and Turkish side.

With situation C, it seems like the ruling political party in Turkey can keep themselves in power due to their ability to silence opposing sides. As Americans of course we wouldn't stand for silencing the little guy. Leaving us to side for the Americans.

The Overall Outcome

In general it seems like Turkey is a lot like the US with the exception that in some extreme cases the government can stop something it does not like. As Americans we are quick to criticize this point of view because it gives power to the government that is not abused now but could later be abused. If you think about the results 9 times out of 10, it is probably the better answer under the Turkish system. Some people say that having the level of free speech that we have in this country cause the breeding of bad ideas. Think about it, do kids shot each other in Turkish school? Maybe that is the price we pay for freedom of speech in this country.

Last updated 2000/08/01
This commentary was developed in Spring 2000 by Group 6 of the CS 3604 class based on interviews with Turkish students.