Artist: Theodore Dreiser
Confronting Bodies: Society for the Suppression of Vice
Date of Action: 1915
Specific Location: New York City
Description of Artwork: Theodore Dreiser's autobiographical book, The Genius .
Description of Incident: Anthony Comstock's organization, Society for the Suppression of Vice, successfully suppresses the book.
Results of Incident: In 1923, the book was republished in 1923, with a disclaimer which attempted to address the the vice society's condemnation.
Source: National Association of Artists Organizations
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Name: Hans Haacke at the Guggenheim Museum
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Date: 1985 - 1995
Location: North America
Subject: Political/Economic/Social Opinion
Medium: Installation
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Artist: Hans Haacke
Confronting Bodies: Guggenheim Museum
Date of Action: 1971
Specific Location: New York City
Description of Artwork: "Shalopsky et al Manhattan Real Estate Holdings, A Real time Social System, As of May 1, 1971."
Description of Incident: Haacke's exhibition is canceled at the Guggenheim Museum because his show deals with "specific social situations" not considered art.
Results of Incident: Exhibition remained canceled.
Source: National Association of Artists Organizations
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Name: Mother Earth, anarchist publication
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Date: 1900 - 1925
Location: North America
Subject: Political/Economic/Social Opinion
Medium: Print Journalism
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Artist: Man Ray, Emma Goldman, and Alexander Berkman
Confronting Bodies: United States Government
Date of Action: 1914
Specific Location: United States
Description of Artwork: Anarchist publication Mother Earth; cover designed by Man Ray.
Description of Incident: Publication is repressed by the U. S. Government.
Results of Incident: Unknown
Source: National Association of Artists Organizations
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Name: Pietro Aretino's book Sonnetti Lussuriosi
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Date: 1500 - 1799
Location: Europe
Subject: Religious
Medium: Literature
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Artist: Pietro Aretino (1492-1556)
Confronting Bodies: Christian Church, Pope
Date of Action: 1558
Specific Location: 13
Description of Artwork: Pietro Aretino's book Sonetti Lussuriosi, (otherwise known as La Corona di Cazza) contained illustrations of various sexual positions, "Posizioni." The illustrations were done by Giulio Romano, which he created from Aretino's verse.
Description of Incident: In 1527 Pope Clement VII condemned and had suppressed every edition of his Sonetti Lussuriosi which had been published in 1524.
Results of Incident: In 1558, the book went on the Vatican's first index of forbidden books.
Source: Village Voice, Onan the Barbarian, October 19, 1993
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Name: Mae West, "Klondike Annie"
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Date: 1926 - 1950
Location: North America
Subject: Explicit Sexuality
,Other
Medium: Film Video
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Artist: Mae West
Confronting Bodies: Motion Picture Producers and Distributors Association
Date of Action: 1935-1936
Specific Location: Hollywood, New York
Description of Artwork: Mae West's film "Klondike Annie" as described by Ramona Curry: "The film narrative opens in San Francisco's China town, where West's character is held captive as the mistress of a Chinese night club owner, Chan Lo. Doll escapes, killing Chan Lo in self-defense to do so, and embarks on a freight ship to Nome Alaska. En route, the captain of the ship, Bull Brackett (Victor McLaglen) becomes enamored of her. Doll initially shows little interest in Bull, but when he discovers her identity, Doll accepts his attentions in order to prevent his turning over to the authorities. To avoid being arrested by the police patrolling the Nome harbor, Doll assumes the guise of a pious settlement worker, Annie Alden, who has just died on board. In this masquerade, Doll packs the Nome settlement house and enlivens the services with rousing song and good-natured admonitions to the miners to give up drink and live right. The policeman assigned to watch for the wanted woman sees through Doll's disguise, but, fortunately for her, not before he falls hopelessly in love with her. Meanwhile, Bull threatens to kill Doll and the policeman if she doesn't come away with him. She eventually chooses to leave with Bull, but asks him too direct the ship not to the South Seas but back to San Francisco so that she can be legally cleared for having cleared Chan Lo in self- defense."
Description of Incident: The MPPDA was responsible for monitoring scripts before films went into production. The key sections of the Production Code the MPPDA used are "Law natural or human shall not be ridiculed, nor shall any sympathy be created for its violation," furthermore, "The sanctity of the institution of marriage and the home should be upheld." Ramona Curry maps out the negotiation process between MPPDA and the producers of "Klondike Ann" in her article "Mae West as Censored Commodity: The case of "Klondike Annie", Cinema Journal 31, No. 1, Fall 1991. " ...The initial screening of "Klondike Annie" elicited rigorous monitoring from the PCA (Production Code Administration) for its implications of interracial sex, representations of torture and unpunished murder (which undermined the codes principle of 'compensating moral values'), and for casting West as a prostitute... " ...Concern about the sexual behavior of West's character emerges as a prime issue from the earliest correspondence. A letter at the outset of production to Paramount liaison John Hammell to Will Hays, then visiting in California promised, 'The ending of our story will be a romance between West and one of the characters in our picture, and it will indicate for the future a normal life and nothing that will bring condemnation from the most scrupulous.'(June 29, 1935) " ...Hay's response a week later expressed concern about the sexual morality of West's character: 'We assume that there will be no suspicion of loose or illicit sex relationships between Miss West and the Chinese gambler or any of the characters in your story; rather as is suggested in the discussion here, it will definitely be indicated that the woman whom Miss West represents is basically good.' (July 2, 1935) " ...In memos written between September and October 1935 (the film's production went from June to December 1935), Joseph Breen required a number of changes in the script and in song lyrics and repeatedly cautioned the studio about maintaining decency in costuming and camera framing and especially in West's style delivery in "Klondike Annie"... For example, West was prohibited from saying, 'I'm sorry I can't see you in private,' while looking the young detective (Phillip Reed) up and down; other West lines that Breen marked for deletion included 'Men are at their best when women are at their worst'... " ...Upon viewing the film, Breen called for several cuts in scenes implying sexual desire or activity between Brackett and Doll, but granted a PCA certificate of approval on 31 December 1935."
Results of Incident: "The controversy began immediately upon Hollywood previews of the film in early February, when Breen learned that Paramount was exhibiting a print containing material that had been deleted from the version of the film approved by the PCA. Breen immediately rescinded the Code seal and entered into into further negotiations with the studio which resulted in the elimination of 'love talk' and other implications of an 'illicit love affair,' before he agreed on 10 February 1936 to the film's release. "Klondike Annie" opened five days later in a special public preview in Miami and was released nationwide the following week."
Source: Ramona Curry, "Mae West as Censored Commodity: The Case of "Klondike Annie," Cinema Journal 31, No.1, Fall '91 Pg.57-85
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Name: Sullivan vs. New York Times Co.
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Date: 1951 - 1975
Location: North America
Subject: Political/Economic/Social Opinion
,Racial/Ethnic
Medium: Print Journalism
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Artist: New York Times
Confronting Bodies: Sullivan, Police Chief of Montgomery, Alabama
Date of Action: 1964
Specific Location: Montgomery, Alabama
Description of Artwork: A signed ad that appeared in the New York Times in support of civil rights marchers and criticized Sullivan, the segregationist Police Chief of Montgomery, Alabama, for his unfair treatment of the marchers.
Description of Incident: Sullivan sued the New York Times Co. and won massive damages equaling $500, 000 because of minor factual errors in the article.
Results of Incident: The Supreme Court reversed the libel judgment, saying that the First Amendment protected "uninhibited, robust, and wide-open" criticism of public officials, at least unless it could be proved that the critic was deliberately lying or showed "reckless disregard" for the truth.
Source: Sex, Sin and Blasphemy, Marjorie Heins, New Press,'93, NYC
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Name: Lady Chatterly's Lover, D.H. Lawrence
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Date: 1951 - 1975
Location: North America
Subject: Explicit Sexuality
,Other
Medium: Literature
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Artist: D.H. Lawrence
Confronting Bodies: Postmaster General Arthur Summerfield
Date of Action: 1959
Specific Location: United States
Description of Artwork: "Between October 1926 and January 1928 D.H. Lawrence wrote three versions of a novel in which he described the affair of the fictional Lady Constance Chatterly, wife of Sir Clifford Chatterly -an intellectual, writer and Midlands landowner who has been confined to a wheelchair by war wounds- with the estate game-keeper, one Oliver Mellors, the son of a minor. While the book itself, which ends with the lovers each awaiting divorce and looking forward to their new life life together, does not stray conspicuously from Lawrence's general moral and philosophical attitudes, his use of taboo language far exceed anything acceptable in contemporary fiction." The Encyclopedia of Censorship, Jonathon Green, Facts on File, N.Y. C. Pg. 166
Description of Incident: The work is deemed "an obscene and filthy work" that cannot be sent through the mail by Postmaster General Arthur Summerfield.
Results of Incident: The ban, lifted after two lower courts disagreed with Summerfield, is not reinstated by the Supreme Court in 1960. The novel went on to sell two million copies in a year.
Source: New York Public Library, New York City
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Name: Sedition Act, Ratification of the First Amendment
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Date: 1500 - 1799
Location: North America
Subject: Political/Economic/Social Opinion
Medium: Print Journalism
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Artist: Twenty-five Citizens
Confronting Bodies: U.S. Government
Date of Action: 1798
Specific Location: United States
Description of Artwork: Twenty-five Republican editors and printers were prosecuted under the Sedition Act (1798) for "criticizing federalist policies." The law, initiated by president John Adams "..made it a crime, for example, to publish any "false, scandalous and malicious" writing against the government, the Congress, or the President "with intent to defame" them or bring them "into contempt or disrepute" or to stir up sedition." The crime carried a penalty of $2,000 fine and two years in jail." (The First Freedom Today, R. Downs, ALA,Chicago, 1984 Pg.5 ) "even drunks who were overheard condemning (President) Adams were duly charged and fined." (The Encyclopedia of Censorship, Jonathon Green, Facts on File, N.Y.C., Pg. 275)
Description of Incident: The imminence of war between the U.S. and France(1798) coupled with the thousands of French refugees in the U.S. created a wide spread hysteria in the U.S. It was in this climate that the First Amendment would meet its first major challenge, the Sedition Act. The Sedition Act, put into effect not even a decade after the First Amendment was ratified was in opposition to everything that the First Amendment represented. In 1791 the First Amendment, drafted primarily by James Madison, was ratified: "Congress shall make no law...abridging the freedom of speech, or of the press...' "In effect, sedition ceased to be a crime under the broad prohibitions of the First Amendment, though breaches of the peace which destroyed or endangered life, limb or property, were still punishable by law..." With the passing of the Sedition Act "an immediate uproar ensued. One side contended that "a conspiracy against the Constitution, the government, the peace and safety of this country is formed and is full operation. It embraces members of all classes; the Representatives of the people on this floor, the wild and visionary theorist in the bloody philosophy of the day, the learned and the ignorant. Such arguments were met with impassioned pleas for freedom of speech and press, led by Thomas Jefferson and James Madison."( The First Freedom Today, R. Downs, ALA,Chicago, 1984 Pg.5 )
Results of Incident: Thomas Jefferson took office in 1801, pardoning all those convicted under the law. The Sedition Act expired in 1801 with laws passed by the Fifth Congress.
Source: The New York Public Library, New York City
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Name: John Peter Zenger, publisher
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Date: 1500 - 1799
Location: North America
Subject: Political/Economic/Social Opinion
Medium: Print Journalism
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Artist: Artist/Author/Producer John Peter Zenger
Confronting Bodies: Confronting Bodies British Government
Date of Action: Dates of action 1735
Specific Location: Location Colonial America
Description of Artwork: John Peter Zenger was a libertarian who published the newspaper ,The New York Weekly Journal, a newspaper in direct opposition to the government paper, the New York Weekly Gazette. The newspaper published articles concerned with the government and liberty of the press. The issues the British Government were concerned with were described "as having in them many things tending to raise seditions and tumults among the people of this province, and to fill their minds with contempt for his majesty's government."
Description of Incident: "...In October 1734 a committee was appointed to investigate Zenger's newspaper and to look into the charges of seditious libel that had been alleged against it. The committee found numbers 7,47, 48, and 49, which contained (a reprinted article on the liberty of the press), to be libelous as charged and ordered them to be burned. Zenger was arrested and jailed."The Encyclopedia of Censorship, Jonathon Green, Pg. 365 Zenger's was represented in the trial by defense attorney Andrew Hamilton and James Alexander, founder of the American Philosophical Society. Alexander was thought to be one of the first colonial writers to develop a true philosophy on the freedom of the press and speech. Their basic argument "Truth ought govern the whole affair of libels" coupled with the growing distrust of the British Government enabled them to persuade the jury to return a verdict of not guilty.
Results of Incident: The Zenger case was one of the last of its kind to be held before the American Revolution. The case set a precedent for many trials to come concerning freedom of the press and speech. Alexander went on to write on the Zenger Case, A Brief Narrative of the Case and Tryal of John Peter Zenger(1736), which stood as a model for libertarian thought in the 18th century and was used widely by defendants of freedom of speech in Britain and America. As eloquently put by Alexander in one his texts: "Freedom of speech is a principal pillar in a free government: when this support is taken away, the constitution is dissolved and tyranny erected on its ruins."
Source: The First Freedom Today, R. Downs, ALA,Chicago, 1984 Pg.5
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Date Edited: Thursday, March 7, 2002
Name: SLAPPs (Strategic Lawsuits Against Public Participation)
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Date: 1985 - 1995
Location: North America
Subject: Political/Economic/Social Opinion
Medium: Public Speech
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Artist: Ten residents of Westfield
Confronting Bodies: Westfield Partners, Inc.
Date of Action: 1990
Specific Location: Illinois
Description of Artwork: "...In 1990, Westfield Partners, a real estate development firm, purchased land in DuPage County to build a subdivision of single family homes. In order to profit from the venture the developers needed access to a particular roadway. The ten residents who lived along the roadway opposed the development due to the increase in traffic. They petitioned the Highway Commissioner to change the status of the road from a public roadway to private access. After a public hearing on the issue, which the developer failed to attend, the Commissioner decided the issue in favor of the residents..."
Description of Incident: "The developer then sued the citizens in the federal court in Illinois, alleging that they had conspired with the town planners to deprive the developer of property without the due process of law. In addition, the defendants were charged with slander and interference with prospective economic advantage." "In cases such as this individuals and community groups across the United States are being sued for exercising their constitutional "right of petition. These suits known as "SLAPPs" (for Strategic Lawsuits Against Public Participation), are being brought by corporations, real estate developers, government officials, and others against who oppose them on issues of public concern--usually relating to the environment or development, but also encompassing such issues as government spending, corruption and prison construction. SLAPP targets have been sued for engaging in a wide variety of of speech and expression activities: writing a letter to the editor, calling a public official, conducting a public campaign, speaking at a town meeting, testifying before Congress or state legislatures, and filing public-interest lawsuits." The Fund For Free Expression , N.Y.C.,Vol. 1 Issue 6 Pg. 1-6
Results of Incident: "The ten defendants filed a motion to dismiss the suit on the grounds that their First Amendment rights of petition were being attacked. The court granted their motion... The judge sanctioned the developer's attorney for filing a frivolous suit, claiming that Westfield had no basis for arguing that there had been a conspiracy between the defendants and the government to deprive the firm of property without due process. Westfield Partners was required to pay more than $9,00 in attorney's fees to the defendants." The Fund For Free Expression , N.Y.C.,Vol. 1 Issue 6 Pg. 6
Source: The Fund For Free Expression , N.Y.C.,Vol. 1 Issue 6 Pg. 1-7
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Date Edited: Thursday, March 7, 2002
Name: SLAPPs (Strategic Lawsuits Against Public Participation)
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Date: 1985 - 1995
Location: North America
Subject: Political/Economic/Social Opinion
Medium: Public Speech
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Artist: Jacqueline A. Sommer and Linda Tanner
Confronting Bodies: Bunker Resource Recycling and Reclamation, Inc.--DECOM
Date of Action: February,1988
Specific Location: Missouri
Description of Artwork: Jacqueline A. Sommer and Linda Tanner two private citizens of Missouri wrote letters to their local papers which criticized "the operation of an infectious waste incinerator by Bunker Resource, Recycling and Reclamation, Inc.--a subsidiary of the Canadian firm DECOM Medical Waste Systems, Inc. Sommer's letter was published in the Quad County Journal. Tanner's letter was never published, but the editor had given it to the mayor, who had an economic interest in success of the plant." The Fund For Free Expression Vol. 1 Issue 6 Pg. 7
Description of Incident: DECOM responded by filing SLAPPs suits (Strategic Lawsuits Against Public Participation) against the two women. In cases such as this "individuals and community groups across the United States are being sued for exercising their constitutional 'right of petition.' These suits, known as "SLAPPs," (for Strategic Lawsuits Against Public Participation), are being brought by corporations, real estate developers, government officials, and others against who oppose them on issues of public concern--usually relating to the environment or development, but also encompassing such issues as government spending, corruption, and prison construction. SLAPP targets have been sued for engaging in a wide variety of speech and expression activities: writing a letter to the editor, calling a public official, conducting a public campaign, speaking at a town meeting, testifying before Congress or state legislatures, and filing public-interest lawsuits."
Results of Incident: "In addition to the suit, (DECOM) officials led a smear campaign against Tanner which resulted in the loss of her job as a medical technician at a local hospital. The board of the hospital was told that Tanner was bringing live AIDS viruses into the hospital for examination. She was fired without a hearing, despite support from hospital administrators, who said claims about her were absurd. DECOM's suits were unsuccessful and both women countersued (SLAPP-back). In May (1991) a jury awarded Linda Tanner $86 million in damages... The award included a $10 million personal judgment against the owner of the company for the role he played in having Tanner fired." The Fund For Free Expression Vol. 1 Issue 6 Pg. 7
Source: The Fund For Free Expression , N.Y.C.,Vol. 1 Issue 6 Pg. 1-7
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Name: Dr. Carl Muck conductor, Boston Symphony Orchestra
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Date: 1900 - 1925
Location: North America
Subject: Political/Economic/Social Opinion
Medium: Music
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Artist: Dr. Carl Muck
Confronting Bodies: U.S. Government
Date of Action: March 26, 1918
Specific Location: United States
Description of Artwork: A concert of the Boston Symphony Orchestra in Providence, Rhode Island
Description of Incident: "...In November 1917, at a concert of the Boston Symphony Orchestra in Providence, Rhode Island, the conductor ignored the joint request of nine women's clubs that the orchestra play "The Star Spangled Banner" either before or after the program..." Censorship, Princeton 1991 pg. 195 This incident prompted a great deal of press coverage including a verbal response from President Theodore Roosevelt condemning his actions.
Results of Incident: "..By March 26, 1918, Dr. Muck had been placed in jail on the ground that his presence at large was a danger to the peace and safety of the country. He was arrested and held on a Presidential warrant after the Department of Justice had made an extensive investigation "of his record of pro-German sympathies and utterances." And May 1918 saw the former conductor of the Boston Symphony Orchestra in an internment camp at Fort Ogelthorpe, Georgia..." Censorship, Princeton 1991 pg. 195 "...In June 1919, although Dr. Muck was still in the internment camp, plans were being made for his deportation. The next item about (muck) appeared in March 1921. From the safe distance of The Hague in the Netherlands, Muck was able to relate his woes in the Unites States. He denied disloyal actions in America and was said to have stated "I was accused of espionage because I conducted German music and naturally associated with my German compatriots." Censorship, Princeton 1991 pg. 195
Source: Censorship, Princeton 1991 pg. 195
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Date Edited: Thursday, March 7, 2002
Name: J. Stuart Blackton's The Battle Cry of Peace, W.W.I
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Date: 1900 - 1925
Location: North America
Subject: Political/Economic/Social Opinion
Medium: Film Video
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Artist: J. Stuart Blackton
Confronting Bodies: U.S. Government
Date of Action: April, 1917
Specific Location: United States
Description of Artwork: The silent film drama,The Battle Cry of Peace, was promoted as to be both a peace and preparedness film. The plot was based upon (a "fleet of a hostile European power suddenly attacked the United States, and bombarded New York. Invading forces were landed and soon took possession of the city amid scenes of carnage and horror. The leading characters of the play were all killed." Censorship, Princeton 1991 pg. 172
Description of Incident: Blackton (the film's producer) stated that the aim of the picture was to arouse in the heart of every American citizen a sense of his strict accountability to his government in a time of need-and to bring to the notice of the greatest number of people in the shortest possible time the fact that there was a way to insure that peace for which all Americans so earnestly prayed. He held that as a nation we must have the power to enforce and to insure peace." Censorship, Princeton, 1991 pg. 172 As the United States moved from a peace mode to war preparations the film had to undergo major renovations. "In April 1917,...it was announced that all prints of The Battle Cry for Peace had (to be) recalled by Vitigraph and were to be reedited and retitled, so that the picture would stimulate recruiting. Certain of the original titles were deleted because it was felt they might be construed as arguments against war...In Pittsburgh the proprietor of a motion picture theater was arrested in the Spring of 1917 and had for court action under $5,000 bail on a charge of high misdemeanor, after distributing handbills advertising that picture. The authorities held that the handbills alone were calculated to prevent enlistment." Censorship, Princeton, 1991 pg. 172
Results of Incident: The Battle Cry for Peace, was only one of many films censored during this time. Although many of these films were acceptable prewar, the United States Government maintained strict enforcement over any films that could be interpreted as challenges to the war efforts.
Source: Censorship, Princeton, 1991 Pg. 172
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Date Edited: Thursday, March 7, 2002
Name: Samuel Goldwyn's film "Dead End"
[ Edit ]
Date: 1926 - 1950
Location: North America
Subject: Other
Medium: Film Video
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Artist: Samuel Goldwyn, Producer
Confronting Bodies: Production Code Administration
Date of Action: 1936
Specific Location: Hollywood, CA
Description of Artwork: "Dead End," a film about kids in the slums of New York.
Description of Incident: Samuel Goldwyn was warned by Production Code Administration Director, Joseph Ignatius Breen, not to depict "filth, or smelly garbage cans, or garbage floating in the river," in Goldwyn's upcoming film "Dead End." Goldwyn adhered to the PDA demand by implementing his own form of self-censorship. "Goldwyn was shocked when he saw that William Wyler had made the slum and the East River "dirty." Producer and director fought, then compromised: for a scene in which the Kids swam through the mess, the refuse would be "clean." One "Dead End" news release celebrated the property man who halved the fresh grapefruit, washed the carrot greens and scrubbed the assorted debris that kids shared the water with."
Results of Incident: Goldwyn himself supported the Production Code, thus explaining the ease with which he self-censored. Furthermore, "Goldwyn had not laundered the trash to charm Production Code associates; the genteel poverty of Dead End mirrored Goldwyn--and Hollywood--aesthetic of realism edged with guilt."
Source: American Film, L. Leff and J. Simmons, December 1989
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Date Edited: Thursday, March 7, 2002
Name: Vittorio De Sica's "The Bicycle Thief"
[ Edit ]
Date: 1926 - 1950
Location: North America
Subject: Other
,Explicit Sexuality
,Religious
Medium: Film Video
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Artist: Vittorio De Sica, Italian director
Confronting Bodies: Production Code Administration
Date of Action: 1948
Specific Location: Hollywood, Hays Office
Description of Artwork: "Set in the poverty and bleakness of post-war Rome 'The Bicycle Thief' tells a simple but elegant story about a man's desperate search for his stolen bicycle. The picture traces the frantic efforts of Antonio and his 10-year-old son, Bruno, to locate the thief and recover the precious bicycle."
Description of Incident: In spite of the praise and awards "The Bicycle Thief" was receiving from around the globe, Hollywood's Production Code Administration (PCA) was able to find two scenes that it demanded be removed before it would issue its Seal of approval. "The first was a brief, slightly poignant episode in the midst of the frantic daylong search for the stolen bicycle. Antonio's son pauses beside a Roman wall, apparently to relieve himself. His back is to the camera and before he can begin, his father compels him to abandon the call of nature and continue the chase. The second problem, more important to the plot, involved Antonio's pursuit of the thief into a 'house of tolerance.' The run went through the bordello. Showed nothing even remotely sensual. The women were clothed, unattractive and occupied only with their Sunday morning meal." Although neither scene technically violated the official Production Code, Joseph Breen, the PCA's Director, personally opposed the scenes and demanded they be removed before he would issue the film the PCA Seal. Because most cinemas were still owned by the major studios, this Seal was imperative for a films distribution. "The company presidents made the Production Code Seal the passport that the movies needed to enter the largest and most profitable theaters in America. They fined those who distributed or exhibited a picture without the Seal."
Results of Incident: Banking on the films reputation and critics support Burstyn, the film's distributor, began a press campaign to have the Motion Picture Association overrule Breen's decision. The Association supported Breen's decision and demanded that the scenes be removed. Burstyn refused the to make the cuts, and he was forced to release the film without the Seal. "The decision sparked intense criticism of the Production Code Administration. In a two-column New York Times story, "The Unkindest Cut," Bosley Crowther termed the outcome of the appeal 'the sort of resistance to liberalization or change that widely and perilously oppresses the whole industry today... ' In a series of press releases, he accused Breen of applying petty standards that the vast majority of Americans had long sense rejected... " As the support of the PCA began to be challenged by Bursytn and the like "The Bicycle Thief" decision marked the beginning of the end of the PCA's rigid hold on film distribution.
Source: American Film, L. Leff and J. Simmons, December 1989
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