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to the rule, by contrasting them with authority figures who were portrayed in a more positive way.) At first, adhering to the Hays Code was voluntary. Most movie studios obeyed the code so that their films would be approved by state censorship boards that reviewed movies before they were allowed to be released. In 1934, however, the MPAA created the Production Code Administration (PCA), which required all films to obtain a certificate of approval before being released. Under the direction of PCA’s head, Joseph I. Breen, the code was strictly enforced from 1934 until 1954. Breen demanded that studios rewrite or cut scenes that he found offensive or in violation of the code. However, in 1952 the US Supreme Court decided the landmark case Joseph Burstyn Inc. v. Wilson , ruling that motion pictures were protected under the First Amendment to the Constitution. That limited the effect of censorship both by state boards and the PCA. Over time, movie producers became more emboldened to feature content that ran afoul of the code, sometimes releasing films without approval of the MPAA. One of the reasons that producers grew bolder was that television was making inroads into film audiences. Even though television had even more stringent censorship rules in place than the film code, it was more convenient to watch in the comfort of home. Producers feared that without more appealing content, the film industry would grow stagnant.

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Entertainment Controversy Through History