“Je suis Samuel”: The hate crime of Samuel Paty

Charlotte Hanson
Master of Criminology Graduate, Sydney Law School, University of Sydney
Associate, Policyinstitute.net

Samuel was murdered “teaching a class that had to do with the pillars of democracy-
freedom of expression”
– Jean-Michel Blanquer, French Education Minister (2020).


This essay will discuss hate crime, using Perry’s definition of hate crime, which is described as an ‘act of violence and intimidation, usually directed towards already stigmatized and marginalized groups. As such, it is a mechanism of power and oppression, intended to reaffirm the precarious hierarchies that characterize a given social order’ (Perry, 2001, p.10). It will examine hate crime through the ‘real world’ event of the French teacher Samuel Paty, who was murdered by an Islamic extremist in 2020. The case will be used, as an example to ‘fit’ Perry’s definition of hate crime.

This essay will discuss the scope of Perry’s definition and the types of conduct that can be included or excluded. It will examine the questions that the event raised, in regard to which groups, categories and characteristics that are seen to be included or excluded in Perry’s definition. It will also discuss the implications of addressing this event as a hate crime. It will use legislation such as the UK Law Commission consultation paper on hate crime laws to argue that the Paty case and the issues surrounding the case, support this event as a hate crime.

Samuel Paty ‘murder’

Paty was a teacher of geography and history at a school in the Parisian suburb of Conflans-Sainte-Honorine. Paty had organised a class about free speech and expression for his pupils, using two caricatures from the satirical Charlie Hebdo magazine, with other cartoons, the caricatures were of the Prophet Muhammad. It is not clear what caricatures he used in class, although there was a mention in the media of one cartoon of the prophet naked. It is known that Paty had been warned about this, from previous classes, and that one of the pupil’s father had issued a ‘fatwa’ against Paty.

The father posted his own telephone number with an online hate campaign with a video, calling for him to be fired after Paty had used the caricatures in class, on a discussion of ‘free speech’. The teacher warned Muslim students to leave the class, incase they would be offended (Buet & McLauglin, 2020; Henley, 2020). The killer, an 18 year old Chechen refugee, Abdullah Anzorov, asked students outside the school to point Paty out to him, and paid the students. Anzorov decapitated Paty, and shouted “Allahu Akbkar’ (‘God is Greatest’). He refused to put weapons down and posted Paty’s decapitated head with a message to Twitter before he was shot by police, in October 2020.

The father, and a well- known Islamist radical, Abdelhakim Sefrioui, posted videos on social media, campaigning against Paty. M’hammed Henniche, head of the Pantin mosque, also shared the video, as he suggested Muslim schoolchildren were targeted in class. Sefrioui, and the father had links to the Anti-Islamophobia Collective, that was implicated in the attack. As such it is one of the organisations being investigated. Sefrioui, the pupil’s father, Anzorov’s family, and pupils who accepted payment were arrested.

Hate Crime Definition

Perry’s definition of hate crime (HC) regarding violence and intimidation, relates to a prejudice against individuals that have affiliation or membership of a certain group, such as Muslims as they can be seen to be a ‘marginalised’ group. Hate crime relates to the ‘power dynamics’ within society, that ‘reinforces’ the ‘othering’ of individuals perceived as ‘different’. Perry’s guidelines, regarding ‘doing difference’, identifies hate or prejudice as an oppression in society, where normal ‘conceptions of identity’ are seen as ideological, not accepting ‘others’. Thus, HC arises when those in supposed insubordinate inferior positions, try to remove themselves from the inferior ‘structural order’ and are seen as a threat (Chakraborti & Garland, 2012). Perry’s definition suggests that violence is directed at both at the individual victims and their community, in relation to bias-motivated acts.

Perry argues that since the 9/11 terrorist attacks, anti-Muslim victimisation and racial vilification within current society, gives way to hate (Perry & Poynting, 2006). Thus, this concept explains how both sides ‘hate’, as in the Paty incident, the attack was caused by a stigmatized minority group, not the majority group, which with the authorities, the French government fought back. Perry’s definition of HC should include minority groups both as victims and perpetrators of HC, but her earlier analysis describes victims as the minorities, and perpetrators as superior majorities identities, as HC is not exclusively committed by the majority superior groups, within that framework (Chakraborti & Garland, 2012).

Victim Perpetrator Relationships

It is suggested that victims and perpetrators of HC are known to each other either by friends, family, acquaintances, partners, social activities and work-related activities, this all made easier by social media (Mason; 2005, as cited in Chakraborti & Garland, 2012). As in the case of Paty, unknown to him, his attackers were related to the school, as the father of one of his pupils was responsible for his death, as there was evidence that there were text messages between the father and the teenage killer (Henley, 2020). Plus, there were the schoolchildren that pointed out the teacher to the killer.

Chakraborti & Garland (2021) suggest HC perpetrators are ordinary people in their daily lives. These crimes are not commonly committed by ‘organized hate groups, supremacists or far-right extremists. As the attackers were from the minority group, as Muslims, Perry’s ideas can associate those that are from disadvantaged or deprived backgrounds as the perpetrators. As Muslims are seen to be subordinate groups, according to her theories (Perry, 2001, as cited in Chakraborti & Garland, 2012). To understand, rationalise and theorise about HC perpetrators, there needs to be more understanding about ‘prejudice, stereotypes and discrimination’ (Strangor, 2000; Perry, 2003 as cited in Hall, 2015).

Islamophobia and Terrorism

Islamophobia is referred to prejudice, hostility and negative bias towards Islam and Muslims. Since 9/11 there has been an expansion of victimisation, racial vilification, anti-Muslim sentiment, and a rise in ‘Islamophobic’ HC, due to acts of terrorism (Perry & Poynting, 2007). There is also the issue of anti-Muslim HC incidents in retaliation to stereotyping the Muslim community as terrorists by the media, this suggests that the “xenophobic fears of the ‘other’ … that terrorism was endemic to Muslim and Arab culture”
(Ismael & Measor, 2003, as cited in Perry & Poynting, 2007).

The media has contributed to negative anti-Muslim imagery in social media and cartoons, which can be seen to be eight ‘assigned image themes’ which have ‘physiological and psychological traits’ that link to terrorism (Stockton, 1994, as cited in Perry & Poynting, 2007). This imagery stigmatises the ‘other’, and sanctions those to engage in HC and ‘permission to hate’ (Perry & Poynting, 2007). Manifestation of Islamophobia is that the HC is directed to both the victim and their community. The objective of HC is a collective message to all the community, in this case the Muslim community, that they ‘not wanted’ and vulnerable.

Thus, this act against Paty can be seen as a HC, due to the conduct and behaviours associated with HC, such as harassment, assault, resulting in his death. This can also be seen as an act of revenge, an act of hostility and a terrorist act. Although there was no evidence so far of involvement of a terrorist group, as the killer claimed responsibility for the act.

Conduct and Characteristics

HC is not a crime motivated by hatred, but by prejudice or bias, it can be seen to be a ‘learned’ behaviour, bias or prejudice. HC offences can be offences of a criminal nature, offences such as harassment, assault or ‘criminal damage, they can also be hate speech offences, that incite ‘hate’, ‘stirring up hatred’ for example abusive, threatening or insulting behaviour (Law Commission UK, 2020, p5). An HC offence can be seen, when a victim is targeted on the framework of any ‘protected characteristics’ such as race, gender, religion, disabilities, age, ‘sexual orientation and transgender identities’ (Law Commission UK, 2020).

The offences mentioned relate to an offence that is either “motivated by hostility” or “demonstrated hostility” to ‘the protected characteristic’ (Law Commission UK, 2020, p3).
In regards to hate speech offences, abusive speech offences are assigned under criminal offences, aggravated on the “hostility” components, and dealt with under the Public Order Act 1986; and any communication offences under the Communications Act 2003, or under the Malicious Communications Act 1988. In regard to the Paty HC, there is no specific legislation to deal with this offence, unless the HC had a religious or racial motive.

It can be argued that there was a religious motive by the Muslim community that was involved. The father, Sefrioui, a known Islamic radical, and M’hammed Henniche, the head of the mosque. Between them they issued a ‘fatwa’, and an online hate campaign, with Paty’s name and details on Facebook, with a phone number of the father, given out on social media, for what purposes than to hire a killer, Anzorov, a young radical Islamic extremist to deal with Paty.

This HC, Paty’s murder suggested that new legislation was needed in France and the EU (Henley, 2020). The complexity of this case is that the present legislation only deals with the victim targeted on the principle of a protected characteristic, religion would suffice, but it would have to be proved that the offence was ‘motivated by hostility’ towards the protected characteristic of religion. The current legislation in regard to this type of offence does not include murder, unless Paty’s case is proven to be a religiously motivated HC. If Paty was seen to be of another religion, and or of another ethnicity such as Asian or Chinese origin, then the case could be argued that it was religiously and racially motivated. It can be argued that also that there were offences committed under the Communications Act 2003, s127, and the Malicious Communications Act, s1, due to the use of online abuse directed at Paty.

Event as a Hate Crime under Perry’s Definition

Perry’s definition of this event as a HC, demonstrates the impact of targeted violence that can be seen to be a structural response to ‘difference. It also demonstrates the wider social harm to ‘societal norms and values’. The event reveals significant harm to both sides. HC offences exhibit multiple types of harm, in this event. Harm to the direct victim, Paty; the victim’s group including family, friends, and associates; harm to other targeted communities such as other Muslim and other groups (Iganski, 2001, p.629, as cited in Perry, 2015). The implications of this event are that the French government and authorities have targeted Islamic groups such as the Collective Against Islamophobia in France (CCIF), and other groups that promote radical Islamism, this further segregates the communities.

In conclusion, there seems to be need for updated hate crime legislation, which needs to include more categories to keep up to date with HC and violent extremism, to address both ideological and religious forms of motivated bias HC, which can develop into terrorism and cause more mistrust amongst the communities.


Buet, P., & McLaughlin, C., E. (2020). Samuel Paty beheading: Teacher’s slaying sparks
protests across France. Retrieved from: https://edition.cnn.com/2020/10/18/samuel-
paty-france-protests/index.html on 3rd April 2021.

Henley, J. (2020). France: teacher’s killer ‘exchanged texts’ with father of pupil. Retrieved
From: https://www.theguardian.com/world/2020/oct/20/beheaded-teacher-samuel-

Chakraborti, N., & Garland, J. (2012). Reconceptualizing hate crime victimization through
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Chakraborti, N., & Garland, J. (2015). Hate Crime: Impact, Causes & Responses.
London: Sage Publications, p3-6.

Hall, N. (2015). ‘Understanding Hate Crimes: Perspectives from Wider Social Sciences’,
In Hall, N., Corb, A., Giannasi, P., & Grieve, J., The Routledge International
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Iganski, P. (2001). Hate crimes hurt more. American Scientist, 45 (4), pp627-638.

Ismael, T., Y., & Measor, J. (2003). ‘Racism and the North American Media Following 11
September: The Canadian Setting’, Arab Studies Quarterly, 25 (1/2), pp101-136.

Mason, G. (2005). Hate crime and the image of the stranger. British Journal of
Criminology, 45 (6), pp837-859.

Perry, B. (2001). In the Name of Hate: Understanding Hate Crimes. London: Routledge.

Perry, B., & Poynting, S. (2007). Climates of Hate: Media and State Inspired Victimisation
Of Muslims in Canada and Australia since 9/11. Current Issues in Criminal Justice,
19 (2), pp151-171.

Stockton, R. (1994). ‘Ethnic Archetypes and the Arab Image’ in Ernest McCarus (eds),
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Strangor, C. (ed). (2000). Stereotypes and Prejudice. Philadelphia: Psychology Press.


UK Law Commission, 2020, Hate Crime Laws: A Consultation Paper Summary. Retrieved
from: https://s3-eu-west-2.amazonaws.com/lawcom-prod-storage-
Communications Act 2003, s127
Malicious Communications Act, s1

Videos and Images:

“Teacher decapitated in Paris named as Samuel Paty, 47” Kim willsher, sun 18 oct 2020
The Guardian

President Macron addressing public

The views expressed in this article is solely that of the author’s and does not represent that of Policyinstitute.net and its entire staff.

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