The need for The Hays Code was the next to go. The Paramount decision had already weakened it by causing the rise of independent “art house” theaters that could show foreign and independent films that weren’t covered by the Code. The real crippling blow to film censorship, however, was another landmark Supreme Court decision, the 1952 case of Joseph Burstyn, Inc. v. Wilson, also known as the Miracle Decision after the name of the film, The Miracle by Roberto Rossellini. That film had controversial Catholic imagery and themes, with an ironic reworking of the Virgin Birth. The Miracle Decision declared that film was an artistic medium protected under the First Amendment, thereby eliminating the threat of government censorship that had led to the implementation of the Code in the first place. Since there was still no film ratings system other than the unofficial one of the National Legion of Decency (whose influence was on the wane by the time The ’60s rolled around), films would be billed as “Recommended for Adults Only,” and more and more theater chains were willing to show them.
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