Neither society is 100% free; that's the point, really. The trade-offs like this that the American system has selected seem insane.
> They have very specific speech restrictions around things like Holocaust denial, not "flagrantly criticizing the government".
Germany, maybe. In UK a scottish man was arrested for tweeting "The only good brit soldier is a deed one, burn auld fella, buuuurrn." about the late Tom Moore. Apparently being arrested for offensive tweets is not uncommon in the UK. Lots of arrested around the time of the queen's death for making fun of the monarchy/dead queen.
https://en.wikipedia.org/wiki/Novak_v._City_of_Parma
> Novak v. City of Parma, No. 21-3290, is a 2022 decision of the United States Court of Appeals for the Sixth Circuit granting qualified immunity to the city of Parma, Ohio, and its officials for prosecuting Anthony Novak over a Facebook page parodying the Parma Police Department's page. As of December 2022, the case is pending certiorari before the Supreme Court of the United States.
> cherry-picked quirks of individual states
Civil forfeiture? Healthcare? Incarceration? Paid leave? These are each widespread national problems in the US.
Also in the UK being arrested doesn’t equate to being punished, legally the police have to arrest you before you can be questioned.
Googling Heinrich Bücker doesn't turn up much other than "World Socialist Web Site", and it appears Germany permits opposition to war just fine; https://www.youtube.com/watch?v=xa0PevmD6EI
I'm not super familiar with Norway's speech protections, but it has a smaller population than the US state of Maryland, so it seems to be the exception more than the rule or at least not an easily scalable solution to America's problems. Saying "[Insert Scandinavian country proves it's possible]" is like saying "Look at how well Hacker News is moderated! Facebook and Twitter should take notes on how to do it right and fix the moderation issues with their services."