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So if you commit a crime with the intent of pissing someone off it's automatically a hate crime? Uhh...
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No, it has to deal with racial/religious tensions as well. He threw a Koran in the toilet. A holy book. If he did it to show his contempt for the religion, then yes, I can see it being classified as a hate crime. And giving someone the finger isn't a crime. Don't be silly.