In one case, the meme was accurate - the photo, the quote, and its attribution were all accurate, and the cops knew that. It never made it to trial, for obvious reasons.

In the other, it was false information, a grand jury indicted, and a jury convicted. The appeal rested on the government struggling to demonstrate a) anyone actively fell for the information and b) the conspiracy element. (https://ww3.ca2.uscourts.gov/decisions/OPN/23-7577_opn.pdf)

Somehow, this distinction is... bias?