Intro

I love movies. I have loved movies all my life. I grew up on them. When I was eight years old, I managed to convince myself I would make movies when I grew up. Now I am in the process of getting a degree in Film Studies. I write about film more than ever before, partly because I have to for my classes, mostly because I enjoy it, because I have something to write about. Sometimes it helps me understand the film better; sometimes it helps me understand myself better.
I created this blog as a place to showcase my work, and also as an incentive to keep writing reviews, analyses, and essays over breaks, when there’s no one here to grade me.
I have tried many times, and failed, to explain in a coherent manner why it is that I love films. Here is my best—and most coherent—guess.





Sunday, March 9, 2014

Censoring Cinema: Hollywood's Production Code




“Suspicious of a flickering amusement that mesmerized the commonest of folk and the dullest of immigrants…, reformers of all stripes viewed the motion picture as a gateway to personal damnation and social deviance… the motion picture medium, if left to its own devices, was more liable to pollute and degrade than refine and uplift,” Thomas Doherty writes in Hollywood’s Censor: Joseph I. Breen & the Production Code Administration (32). These were the sentiments that led the film industry to adopt the Motion Picture Production Code in the 1930s, a form of self-censorship that regulated film content for over three decades. “Just as a single lustful spasm in a brothel might sow the seeds of disease and dissipation,” the author continues, “a brief session at a nickelodeon might undo years of educational guidance and moral instruction” (32). But the reasons behind adopting and enforcing the Code were varied, ranging from morality to economics, from religion to the need to protect the industry from government censorship. The effects the Production Code had on film content were as diverse as the reasons for adopting it. Although the Code was never considered unconstitutional—because films were not protected under the First Amendment until 1952—the document undoubtedly encroached on the motion picture industry’s right to expression and free speech. 


The Motion Picture Production Code was a set of guidelines governing the treatment of crime, violence, sex, profanity, and other questionable subject matter. The Production Code Administration (PCA), founded in 1934, and before it the Studio Relations Committee (SRC)—both branches of the Motion Picture Producers and Distributors Association (MPPDA), which became the Motion Picture Association of America (MPAA) in 1945—were developed as a response to the perceived decline of moral standards in film.

New considerations had been born with the coming of sound in the late twenties and the realism it added to the cinema; now that movies could “talk,” sex and violence drew closer to real life. “Sound called into question Hollywood’s suitability for general consumption,” Ruth Vasey writes, “both vertically across age groups and horizontally across ethnic and geographic boundaries” (100). A series of scandals involving the film industry also put Hollywood in the crosshairs of an angry army of moral crusaders. “Famous directors turned up dead, matinée idols shot heroin (and each other), doe-eyed ingénues were rousted from sordid love nests,” and comedian Fatty Arbuckle was accused of rape and murder; these incidents “solidified Hollywood’s reputation as a sun-drenched Sodom luring Midwest farm girls to a fate worse than waitressing” (Doherty, Hollywood’s Censor 33).

In response, in 1922 Hollywood enlisted the services of Will H. Hays, an Indiana lawyer, Presbyterian elder and Republican who served as Postmaster General under Warren G. Harding. The formerly semi-known ex-cabinet officer became a household name, assuring the public that, “The old careless, helter skelter days are over” (Doherty, Hollywood’s Censor 35). The “Don’ts  and Be Carefuls,”a precursor to the Code, were developed by Hays in collaboration with the studio heads from MGM, Fox, and Paramount between 1927 and 1929. Hays created the SRC to see to its implementation, but these guidelines were not successfully enforced.

Hays was concerned with cinema’s effect on the “impressionable classes” of children and immigrants, as well as the conservative rural population, “the vast majority of Americans, who do not fling defiance at customs and conventions, but who cling with fine faith and devotion to the things that are wholesome and healthy” (Vasey 103). Although the PCA was a secular organization, religion—more specifically Roman Catholicism—strongly influenced the conception, application, and enforcement of the Code. “A deeply Catholic text, the Code was no mere list of Thou-Shalt-Nots but a homily that sought to yoke Catholic doctrine to Hollywood formula: The guilty are punished, the virtuous are rewarded, the authority of church and state is legitimate, and the bonds of matrimony are sacred” (Doherty, “Church’s Reach Diminished”). The organization had strong ties with the Legion of Decency, whose belief was that “the pest hole [Hollywood] that infects the entire country with its obscene and lascivious moving picture must be cleaned and disinfected” (Tropiano 53).

Will Hays and the second most famous set of ears in Hollywood after Mickey Mouse's
The Production Code had no one author; it was a collaborative effort between Hays, Joseph I. Breen, a number of studio heads, and its official creators, Lay Catholic Martin Quigley and Jesuit priest Father Daniel A. Lord. The document is known inaccurately as the Hays Code after Will Hays, who was only in charge of the SRC until 1934. Breen, the keeper of the Code and director of the PCA form 1934 to 1941 and from 1942 to 1954, was a conservative Irish Catholic active in church affairs. The Code’s ties to religion prompt Doherty to compare it to the bible: “Conceived in faith and invested with a sacred aura, the Code would be likened to another text, the Bible, and metaphors of print-based religiosity would waft around it like incense: the commandments, the tablets, the gospel. Like different translations of scripture, the verses of the Code might be refined and rephrased but the fundamentals were eternal and unalterable” (Hollywood’s Censor 41).

Authors of the Code might seem naïve to think moviegoers’ minds were so easily malleable and influenced, but there was ample reasons for adopting it that had nothing to do with morality and Catholicism. The Code was developed originally as a public relations gesture designed to placate the Legion of Decency and curtail the agitation for state censorship. Economics, not morality, was and is the primary motivation for self-regulating; since the 1920s,  the threat of government interference has loomed over the industry and continues to serve as the motion picture industry’s primary incentive for keeping a close eye on its own backyard. As commercial speech, movies were not granted protection under the First Amendment until the 1952 Supreme Court “Miracle Decision,” so Hollywood sought a way to regulate itself that would minimize state interference.

Fed up with censors asking for costly cuts, in 1915 one company had sued a state censor board, taking the argument all the way to the Supreme Court (Doherty, Hollywood’s Censor 32). The case, Mutual Film Corporation v. Industrial Commission of Ohio 236 U.S. 230 (1915) backfired. The majority opinion reads, “It cannot be put out of view [that film exhibition] is a business pure and simple, originated and conducted for profit, like other spectacles, not to be regarded… as part of the press of the country or as organs of public opinion. They are mere representation of events, of ideas and sentiments published and known, vivid, useful, and entertaining no doubt, but… capable of evil, having power for it, greater because of their attractiveness and manner of exhibition.” The consequences of denying motion pictures First Amendment protection were immediate and far-reaching. New York was the first state to institute a censorship board in 1921, followed shortly after by Virginia and six other states by the advent of sound in 1927. “Backed by the highest court in the land and freed from pesky First Amendment considerations, state and municipal censor boards proliferated” (Doherty, Hollywood’s Censor 33).

The Production Code was officially adopted and ratified by the MPPDA in 1930 but not enforced until 1934, when Breen took over form Hays, and an amendment to the Code was passed, stating that every film needed the PCA official “Seal of Approval” in order to be released. What we have come to call the Pre-Code era—its name slightly misleading—dated from roughly 1930 to precisely July 15, 1934; it was a period of almost unprecedented freedom in motion pictures. “The phrase evokes a time when trigger-happy gangsters, wisecracking dames, and subversive rebels, male and female, ran wild through the lawless territory of American cinema” (Doherty, Hollywood’s Censor 52). Threatened by the Depression, Hollywood flouted the Code, making adult movies that formed a “complex, diverse, socially responsive” cinema (LaSalle, qtd. in Vieira). Apart from making films more realistic, sound also changed dramatically the content of motion pictures. Now hit-stage productions, best-selling novels, and short stories could be adapted, and oftentimes their themes clashed with the Code’s standards (Vasey 102).

The titles of films made during this period are enough to support this view: Red-Headed Woman (1932) and Baby Face (1933), in which predatory trollops went horizontal for upward mobility; Little Caesar, Public Enemy (both 1931), and Scarface (1932) dealing with the mob, murder, bootlegging, and charismatic criminals; I Am a Fugitive from a Chain Gang (1932) and Heroes for Sale (1933), both contemptuous of legal authority, Howard Hughes’ Hell’s Angels (1930), DeMille’s Madam Satan (1930), and many, many others.

And then there were the love goddesses: Dietrich, Garbo, Harlow, and, of course, Mae West. In films like The Blue Angel, Trouble in Paradise, Dinner at Eight, Blonde Venus, She Done Him Wrong, Morocco, Shanghai Express, and Queen Christina (all made between 1930 and 1933), these women played “sensualists without guilt”; they pursued men without becoming freaks, villains, or even being European, and they weren’t seen as unfeminine or predatory (Haskell 91).

“Striding through every scene with the rhythmic tread of a transvestite dinosaur, bursting out of a wardrobe so tight she never sits,” West was a composite of sexual types, an object of sex turned subject who flipped the male gaze on its head (Vieira 116). “The poster girl for pre-Code bawdiness,” she parodied the Production Code through her very being (her size, voice, humor, aggressiveness, and swagger), along with our conceptions of masculinity and femininity (Doherty, Hollywood’s Censor 67, Haskell 115-117).

During this period, The Hays office had no authority to ban or censor film content or order the studios to remove material, instead reasoning, negotiating, and sometimes pleading with producers, oftentimes ineffectively. In 1930, there was still no standardized procedure for the pre-approval of movies; the SRC depended on the studios’ willing cooperation. Furthermore, appealing a decision by the SRC meant appearing in front of a board of three producers. “The jury pool was tainted… the men who sat in judgment of each other knew when to nod and when to wink. Mutual back-scratching, not impartial enforcement, was the rule” (Doherty, Hollywood’s Censor 46-47).

The process changed dramatically after Breen took over in 1934. Before production, studios were required to submit a plot synopsis, treatment, and all drafts of the screenplay so PCA could decide whether the material was acceptable under the provisions of the Code; sometimes the novel or play the film was based on had to be pre-approved, and then all script revisions, songs, and costumes had to be passed. In post-production, a final print would be submitted to see if additional cuts were required.

“This Code is a moral Code,” Breen wrote in 1934. “Its principles, for the most part, are built upon the basic concepts of Natural Law. No other industry, so far as I know, has undertaken to pattern its products in conformity with the basic tenets of decency and morality” (Tropiano 58). The document had two parts, the first made up of “General Principles” and “Particular Applications,” the second describing the underlying rationale for the guidelines. The reasoning was that the cinema, as a form of artistic expression and mass entertainment, can be “helpful or harmful to the human race,” “morally good” or “morally evil,” and that its very nature and its capacity to reach a large audience necessitated for a strict regulation. (Tropiano 57) “In general, the mobility, popularity, accessibility, emotional appeal, vividness, straightforward presentation of fact in film make for intimate contact with a larger audience… Hence the larger moral responsibilities of the motion pictures” (Tropiano 57).

Drug use was a no-no; drinking could only be presented when central to the character development or plot; white slavery, miscegenation, “sex perversion” (homosexuality), sex hygiene or venereal diseases, nudity, child birth, suggestive dancing, profanity, obscenity, vulgarity, the selling of women, hanging or electrocutions as punishment for crimes, cruelty towards animals or children, and surgical operations were off limits; religious officials and law enforcement agents could never be ridiculed; crime and sex were to be treated with the utmost care. The effects on film content were monumental.

These strict, impassable guidelines and their enforcement encouraged filmmakers to introduce levels of suggestion and ambiguity into their work, and characterize adult themes through ellipsis and innuendo, so as not to be accused of educating innocent viewers in methods of sexual or criminal behavior (Vasey 101). The implementation of the Code resulted in a predictable cinematic world of certainties in which crime had to be punished under all circumstances, and never shown in a positive or sympathetic light. Methods of crime, including theft, robbery, safecracking, dynamiting of trains, mines, and buildings, murder, arson, and the use of firearms, should never be explicit, “having in mind the effect which a too-detailed description of these may have on the moron” (Vasey 113).

As an example, The Roaring Twenties (1939) focuses on gangster Nick Brown (played by Paul Kelly), yet the mob or bootlegging are never mentioned. Instead, Mr. Brown, member of “a syndicate that’s running all the high-class merchandise that’s being sold in this country,” is introduced in a Chicago café eating a large plate of spaghetti; he does not have an Italian name, speak with an Italian accent, or look noticeably Italian, but it is implied he is a part of the Mafia (Sova 143). It was exceedingly difficult to portray a criminal in a bad light while at the same time removing violence and murder from the screen. The result was a very different kind of crime movie, in which gangsters were replaced with G-men , undercover policemen becoming the main characters and heroes.

In terms of sex, rape and seduction should never be more than suggested; adultery and scenes of passion could only be included when essential to the plot and, when illicit or unconventional, sexual behavior should only be shown in order to be condemned; and sexual transgression for women often resulted in misery and/or death (Sova 133). The predictability and saccharine moralizing platitudes of crime films translated into other genres as well.

Dr. Monica (1934), for example, contained adultery, a pregnant, unmarried woman, attempted abortion, and several clinical discussions about infertility, but passed the PCA revision with flying colors. However, pregnancy is only hinted at through a fainting spell, attempts to lose the baby merely involve heavy drinking and reckless horse riding (before the character even knows she is pregnant), the unmarried woman commits suicide, and her illegitimate baby is adopted by the unfaithful father and his wife, now reconciled (Sova 134-35).

Some filmmakers found ways around the Code. As early as the 1940, there were directors who refused to comply. The infamous dispute over one film spanned the entire decade of the forties; “like an incubus in a recurring nightmare, Howard Hughes’ mangy western The Outlaw reared up again and again to taunt and haunt Joseph I. Breen” (Doherty, Hollywood’s Censor 251). The movie is a “corny, overdrawn, melodramatic,” more-talk-than-action western whose fame derives more form the fact that it introduced Jane Russell—and her 36Ds—to the world and its behind-the-scenes controversies than its onscreen story (Tropiano 65).

“To recycle the inevitable joke,” Thomas Doherty writes, “the objectionable parts of The Outlaw were twofold: Jane Russell” (Hollywood’s Censor 252).While original director Howard Hawks shared the plotline of the movie with the PCA, shooting began before having the script approved. When the film premiered in 1943 in a single San Francisco theater, the reaction was less than encouraging. The Legion of Decency gave it a rating of “C” (for Condemned), and Breen found that, “Through almost half the picture [Russell’s] breasts, which are quite large and prominent, are shockingly emphasized and, in almost every instance, are very substantially uncovered. So far as we know there is no possible way to bring this picture within the provisions of the Production Code…” (Sova 235).

In 1946, Hughes decided to go ahead and release the movie without any cuts, and the  advertising turned to exploitative, sexually charged images and slogans ranging from “How would you like to tussle with Russell” and “What are the two great reasons for Jane Russell’s rise to stardom?” to “That Picture Not for Faint Heart” and, perhaps the lowest point of the campaign, a skywriting plane that flew over Los Angeles drawing two circles with dots in the middle (Tropiano 67-68).

Breen promptly revoked the film’s Seal of Approval. The state censors picked up where the PCA left off, soon banning the film in state after state. Hughes sued the MPPDA in the U.S. District Court of New York City, charging that the association was in violation of antitrust laws and for restraint of trade. The Court reached its decision in Hughes Tool Co. v. Motion picture Assn. of America, 66 F. Supp. 1006 (S.D.N.Y. 1946) on  June 27, 1946, upholding the right of the MPAA to revoke the Code Seal for Hughes’ defiance of the Advertising Code. Judge D. J. Bright wrote, “Experience has shown that the industry can suffer as much from indecent advertising as from indecent pictures” (Sova 236).

Although the director conceded to the re-edits by 1949, the original version of the film earned $5 million at the box office, becoming the highest grossing film for Universal of the decade. Hollywood filmmakers who had begun their fight against the PCA now had an indisputable financial incentive, and it was clear the Breen Office was not representing the viewing public’s values.

The box office success of films released without a seal, however, was only one of the factors threatening the Code. The shifting social and moral climate and changing values towards issues such as adultery, prostitution, and miscegenation took their toll by the mid-fifites. Television and a decline in film attendance prompted Hollywood to try to offer the theater audiences something they could not get in their own living rooms, which often meant sex and violence.

More important perhaps in breaking the Code was the burgeoning influx of foreign films not bound by the guidelines of the PCA. During the studio era, the major studios (MGM, Paramount, RKO, Twentieth Century Fox, and Warner Brothers) produced, distributed, as well as owned the first-run theaters where their films were exhibited, while the minors (Columbia, United Artists, and Universal) had an agreement with the majors to exhibit their films. In United States v. Paramount Pictures, Inc 334 US 131 (1948), the Supreme Court ruled in an 8-0 decision that studios could not own theaters, finding vertical integration in violation of anti-trust laws. This meant that movie theaters were free to show the more morally lenient foreign works.

Roberto Rossellini’s Italian import Il Miracolo, starring Anna Magnani, was one of the most controversial films of the fifties, and one that prompted a landmark Supreme Court Decision in1952, four years after its release. Paired with the director’s The Human Voice under the title L’Amore, the movie premiered at the Venice Film Festival in 1948. It received mixed reactions in Italy. In October 1948, the Catholique Cinematographic Center, the Vatican’s censorship agency, determined The Miracle “constitutes in effect an abominable profanation from religious and moral viewpoints,” but the Italian censors cleared the film, which was praised by The Christian Democratic Party, in essence the Catholic party in Italy, as “a beautiful thing, humanly felt, alive, true, and without religious profanation as someone has said, because in our opinion the meaning of the characters is clear and there is no possibility of misunderstanding” (Sova 198).

Joseph Burstyn and his partner Arthur Mayer secured the U.S. distribution rights and packaged The Miracle with two French shorts under the title Ways of Love (1950) (Tropiano 85). The film was exempt from the PCA seal of approval, but passed the Customs Bureau, the National Board of Review, and the New York Censor Board without difficulty.

Its plot centers on a poor, confused peasant woman named Nanna (Magnani), who encounters a handsome stranger (Frederico Fellini) while herding her goats on a mountainside and is convinced he is St. Joseph. The man shares his wine with her; she falls asleep, and when she wakes he is gone. Discovering she is pregnant, Nanna believes it is by the grace of God, but no one in the village believes her; the younger villagers follow her in the streets and mock her pitilessly. While Rossellini’s intention was to represent the “miracle” in her redemption and regaining of sanity through birth and maternal love, Catholic communities in New York, led by the Legion of Decency, started to boycott the film as sacrilegious, and its exhibition license was soon revoked.

Burstyn sued, arguing that this violated his First and Fourteenth Amendment rights, and the term sacrilegious “provided no guidelines for the scope of administrative authority,” and took his case to the Supreme Court. (Sova 199-200). The lengthy decision in Joseph Burstyn, Inc. v. Wilson, 343 U.S. 495 (1952) supported that the term is, indeed “constitutionally vague… It is not necessary for us to decide, for example, whether a state may censor motion pictures under a clearly drawn statute designed and applied to prevent the showing of obscene films… We hold only that under the First and Fourteenth Amendments a state may not ban a film on the basis of a censor’s conclusion that it is ‘sacrilegious.’” The “Miracle Decision,” as it’s come to be known, overruled Mutual Film Corporation v. Industrial Commission of Ohio 236 U.S. 230 (1915), concluding on May 26, 1952 that, “Expression by means of motion pictures is included within the free speech and free press guarantees of the First and Fourteenth Amendments.”

The decision struck down all criteria for censorship other than obscenity, and had a direct impact on five other cases involving movies: La Ronde (1950: banned in New York), M (1951; banned in Ohio), Pinky (1949; banned in Marshall, Texas), The Moon Is Blue (1953; banned in Kansas, Maryland, Ohio, Jersey City, and Milwaukee) and Native Son (1951; banned in Ohio) (Tropiano 85). Terms such as indecent, immoral, cruel, corrupt, or conducive to crime were determined too broad to function as significant criteria for banning or censoring films (Sova 201). This marked the beginning of the end, although it would take more than a decade before all state and local censorship boards would be completely dismantled and the Production Code would be replaced by the current rating system.

Even before the landmark “Miracle Decision”, however, some films, like Jean Negulesco’s Johnny Belinda (1948) and Elia Kazan’s Pinky (1949) were flouting the Code by depicting rape and miscegenation, respectively. Kazan’s Pinky tells the story of a young black girl from Mississippi who moves to Boston after high school to earn her nursing degree and work, where she “passes” for white and gets engaged to a white doctor. The film, initially titled Quality, was meant to expose the ugly realities of racism in America, but the version which got released toned down the interracial romance. Banned in Marshall, Texas, the producers took the case to the Supreme Court, which found the ban on exhibition unconstitutional (Sova 239-240). In the concurring opinion, Justice William O. Douglas wrote, “the evil of prior restraint, condemned by Near v. Minnesota, 283 U.S. 697, in the case of newspapers and by Burstyn v. Wilson, 343, U.S. 495, in the case of motion pictures, is present here in flagrant form. If a board of censors can tell the American people what is in their best interests to see or to read or to hear… then thought is regimented, authority substituted for liberty, and the great purpose of the First Amendment to keep uncontrolled the freedom of expression defeated” (Zenith International Film Corp. v. City of Chicago, ILL., 183 F. Supp. 623 (1960)).

In 1954, Kazan’s masterpiece of social realism On the Waterfront, starring Marlon Brando, used the previously unblurtable word “hell” in an incendiary context—spat in the face of a Catholic priest (played by Karl Malden) not once, but twice. Breen pleaded with the MPAA himself to keep the word in: On the Waterfront, he wrote, was “an astounding motion picture which deals, powerfully, with the problem of corruption among the waterfront unions in New York City, and the solution to these problems, largely through the leadership of a courageous priest… Although the letter of the law is violated, the intent of that section of the Code which deals with the use of the word “Hell” is not… [The word] is not used in a casual manner, as a vulgarism or as a flippant profanity. It is used seriously and with intrinsic validity” (Doherty, Hollywood’s Censor 320-321). It was clear that the Code was beginning to crack.

But it was Otto Preminger, not Kazan, who gave the PCA one of its biggest headaches of the decade with the triple threat of The Moon Is Blue (1953), The Man with the Golden Arm (1955), and Anatomy of a Murder (1959). The Man with the Golden Arm presents a stark and unglamorous look at the world of heroin addiction, although the Code clearly forbade any film to deal with illegal drug use. Preminger decided to release it without a seal of approval, and the film was critically and financially successful. His decision signaled a new trend in the film industry of directors and producers refusing to compromise on their work, instead opting to take the risk of releasing it without approval.

As a result of this stand, and in conjunction with changing social mores, the PCA agreed to make changes to the Code (Sova 193-194). The first major revision of the Code was approved in December 1956. MPAA president Eric Johnston emphasized his belief that the Code is “a flexible, living document—not a dead hand laid on artistic and creative endeavors” (Tropiano 75). Certain subjects and themes (like drug addiction, kidnapping, abortion, and nudity) were now permitted, if still regulated. The Man with the Golden Arm was quietly granted the seal in 1962 (Sova 194).

The story of Preminger’s Anatomy of a Murder, set mostly in a courtroom, revolves around the killing of a bar owner by an army lieutenant who claims the man raped his wife. Because of its subject matter, it’s not difficult to see why the film ran into the PCA censors. The movie was deemed obscene by the Chicago board of censors for the use of the terms “rape,” “sperm,” “penetration,” and “contraception” in the description of the forced act in the trial testimony; it was subsequently banned in Chicago. Preminger brought suit against the city. Applying the measure established in Roth v. United States, 354 U.S. 476 (1957), requiring that a work must “be judged as a whole in terms of its effect on the average, normal reader or viewer,” Judge Julius H. Miner determined that the Illinois board had “exceeded its constitutional bounds” (Sova 18). The courtroom scene describing the rape, the judge argued, “has the effect of arousing pity and revulsion rather than desire or sexual impure thoughts,” and its explicit nature does not “outweigh its artistic and expert presentation” (Sova 18).

Other films of the period, like Billy Wilder’s Some Like It Hot (1959) and Sidney Lumet’s The Pawnbroker (1964), were released without a seal, or appealed its denial and finally got approved without any cuts, respectively.

In 1966, newly appointed MPAA president Jack Valenti introduced “The Motion Picture Code of Self-Regulation,” which was “designed to keep in closer harmony with the mores, the culture, the moral sense and the expectations of our society”. A precursor to the rating system, it saw censorship as “an odious enterprise,” but stated that certain subjects (evil, sin, crime, nudity, illicit sex, obscenity, profanity, religious and racial slurs, cruelty to animals) should be handled with care (Tropiano 90).

At the same time, the language of this new Code was vague and unassuming, not unlike the list of “Don’ts and Be Carefuls” from 1927. The MPAA unofficially began to classify films at this time instead of leveling the moral playing field for the entire viewing audience (Tropiano 91).The “Suggested for Mature Audiences” label (SMA) was added to films like A Funny Thing Happened on the Way to the Forum (1966), Two for the Road (1966), and Reflections in a Golden Eye (1967), while Who’s Afraid of Virginia Woolf? (1966) carried an even higher age limit, admitting no one under 18 without parent or guardian supervision.

The Classifications and Rating Administration (called The Code and Rating Administration until 1977) founded in 1968 does not technically censor film content, but assigns rating informing viewers of the suitability of its content for children and teenagers in regards to profanity, nudity, sex, violence, subject matter, and themes (Tropiano 53).

As a form of self-censorship, the Motion Picture Production Code limited the film industry’s constitutional right to free speech. Overseen by Hays’ Studio Relations Committee until 1934 and then by Breen as head of the Production Code Administration, these self-imposed, religiously fashioned moral guidelines, adopted for a multitude of different reasons, had far-reaching, wide-ranging effects on American cinema content. Even with the document in place, however, there were filmmakers who found ways around it. Hughes’ The Outlaw, Kazan’s Pinky and On the Waterfront, Preminger’s The Moon Is Blue, The Man with the Golden Arm, and Anatomy of a Murder, and, of course, Rossellini’s The Miracle were some of the films that prompted the dissolution of the Code and its replacement with the MPAA rating system. By the fifties and early sixties the shifting social and moral climate, the threat of television, the box office success of films released without approval, and the influx of foreign films had started to wear down the Code, and its demise was sealed by the decision in Joseph Burstyn, Inc. v. Wilson, 343 U.S. 495 (1952).

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