1932 - 1934: Hays, Breen and the PCA  

In January 1932, Joseph Breen had arrived in Hollywood to oversee its publicity for the Association. His abrasive style constituted a significant shift away from Joy's attempts at consensus. In September Joy left to become a producer at Fox, and was replaced by the former New York censor James Wingate, who proved unable to establish a rapport with any of the studio heads, and paid too much attention to details of elimination rather than wider thematic concerns. Joy's resignation coincided with the first publication of extracts from the Payne Fund Studies, a research program investigating children's attendance and emotional responses to motion pictures undertaken by the Motion Picture Research Council (MPRC), which had become the focal point of Protestant and educational concerns about the cultural effects of the movies. A widely circulated sensationalized digest of the Studies, Henry James Forman's Our Movie Made Children, made the MPRC's demands for Federal regulation a profound threat to the industry. By the end of 1932 nearly forty religious and educational organizations had passed resolutions calling for federal regulation of the industry.

The early months of 1933 comprised the low point of the industry's fortunes. It was rumored that Hays would be replaced with a Democrat after Roosevelt's election, and there was widespread fear that the entire industry was virtually bankrupt. Hays insisted that more than economic action was required to deal with the crisis, and that only a more rigid enforcement of the Code could maintain public sympathy and defeat the pressure for federal intervention. He persuaded the Board to sign a Reaffirmation of Objectives acknowledging that "disintegrating influences" threatened "standards of production, standards of quality, standards of business practice," and pledged them to the maintenance of "higher business standards." The Reaffirmation became the implement with which Hays began to reorganize the SRC. The tone of its correspondence changed: as one studio official explained to his producers, "prior to this time, we were told 'it is recommended, etc.,' but recently letters definitely state, 'it is inadmissible, etc.' or something equally definite." A number of productions then nearing completion, among them Paramount's adaptation of Sanctuary, The Story of Temple Drake and Warners' Baby Face were held up for extensive revisions in addition to those agreed prior to the Reaffirmation. Breen relinquished his other work to concentrate full-time on self-regulation, and established his usefulness to the companies by doing what Wingate apparently could not: providing practical solutions to a studio's problem in applying the Code, and thus protecting its investment. From August 1933 he was in effect running the SRC.

Breen was also in almost constant conspiratorial correspondence with Quigley and other prominent Catholics, attempting to involve the Church hierarchy in a demonstration of Catholic cultural assertiveness. By November 1933 they had persuaded the Catholic Bishops to establish an Episcopal Committee on Motion Pictures, and in April 1934 the Committee announced it would recruit a Legion of Decency, whose members would sign a pledge promising "to remain away from all motion pictures except those which do not offend decency and Christian morality." The Legion was not a spontaneous expression of public feeling. Its campaign was delicately orchestrated to achieve a precise objective: the effective enforcement of the Production Code by the existing machinery. Although its principal weapon appeared to be the economic one of a threatened boycott of films or theatres, its real power lay in its capacity to generate publicity. It was designed to intimidate producers, not to inflict major economic damage. It was, indeed, vital to its success that it separate the question of Code enforcement from issues of industry trade practice like block booking, in order to differentiate the Legion from the MPRC and make it clear that the Bishops had "no purpose or desire to tell the picture people how to run their business." It was a very effectively stage-managed crisis, and a complete success in producing its intended results. In June the MPPDA Board revised the Resolution for Uniform Interpretation. The SRC was renamed the Production Code Administration (PCA), with Breen as its Director and an augmented staff. The producer's jury was eliminated, leaving appeal to the MPPDA Board as the only mechanism for questioning Breen's judgment. Each film passed by the PCA would be given a Seal, displayed on every print. All member companies agreed not to distribute or release a film without a certificate. A penalty clause imposed a $25,000 fine for violation of the new Resolution.

Given the public attention being paid to the campaign, it was in the industry's best interests to make a show of atonement. Industry publicity emphasized the scale of the 1934 crisis in order to create a dividing line between "before," when the SRC had been unable to control production, and "now," when PCA "self-regulation" had really become effective. As a result of this need for a public act of contrition, the history of the SRC's gradual implementation of the Production Code was concealed behind a more apocalyptic account. The immediate purpose behind this exaggeration was less to flatter the Catholics (although the Legion of Decency, which operated its own ratings system, remained a powerful influence at the PCA until the 1950s) than to outmanoeuvre those still demanding federal regulation of the industry. But in fact, Breen had largely won the internal battle by March, when Fox, RKO, Universal and Columbia were showing "a definite willingness to do the right thing," and there was "some progress" at Paramount and 20th Century. Only Warners, always the most recalcitrant of the major companies in their attitude to the Code and the MPPDA, had to be brought into line. With the implementation of the agreement in mid-July, conditions tightened further. As in March 1933, a number of films were withheld from release, and drastic reconstruction undertaken: the conversion of Mae West's It Ain't No Sin into Belle of the Nineties being the most prominent. A number of films then in circulation were withdrawn before the end of their release cycle: many more were refused certification over the next few years when companies attempted to re-release them. Other films in production, including The Barretts of Wimpole Street, Bordertown and Imitation of Life underwent substantial modifications; proposed projects, including MGM's plan to adapt James M. Cain's The Postman Always Rings Twice, were rejected. In another important respect production policy had changed dramatically in early, not mid-1934. The wave of Hollywood's adaptation of high-budget literary classics and historical biographies resulted directly from the requirements of the industry's public relations. As well as Max Reinhardt's A Midsummer Night's Dream and Thalberg's Romeo and Juliet, movies like Charge of the Light Brigade and The Buccaneer were also aimed at convincing middle class America of the bourgeois respectability of the cinema.