State v. Mitchell, 169 Wis. 2d 153, 485 N.W.2d 807 (1992)

A defendant convicted of aggravated battery received an enhanced sentence under Wisconsin’s hate crimes statute because he intentionally selected his victim based on race. The majority declared that the statute violated the defendant’s First Amendment right to freedom of thought. Abrahamson dissented. She said that the statute prohibited conduct, not beliefs or expression. “Bigots are free to think and express themselves as they wish, except they may not engage in criminal conduct in furtherance of their beliefs.” In a unanimous opinion, the United States Supreme Court adopted Abrahamson’s view of the law and upheld the statute. Wisconsin v. Mitchell, 508 U.S. 476 (1993).