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?
In both cases the reason someone was persecuted was they offended someone in power. And the system eventually ruled in their favor. That is the similarity.
If you view one of those cases as a bad result, then chances are you are biased.
That said, if you downvote because you have looked into the cases enough to think that that similarity is not valid, and then you can articulate it (like the person I'm replying too did) then I'd consider that fine. (Assuming they downvoted, they may not have.) I may still think there's some bias there, but it's not uninformed bias.
If you can't articulate a reason you want to downvote, then it's bias and emotion fueling your downvote. Which, I don't consider to be a valid reason to downvote.
As a side note, I think we all need to be aware of how similar the things we hear about the "bad" side are. The comments I see about Trump weaponizing the Department of Justice to oppress people is pretty much exactly what I saw said about Biden weaponizing the Department of Justice to oppress people during his administration. I also have seen MANY comments where if you replace "Biden" or "Trump" with the other name, you end up with a comment the other side would make. I think that should trigger some self-reflection. I know I'm still trying to figure out what to think about it.