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Censorship <^<^><^><^^><^<^><^><^> 369
That all exhibitors, producers, and distributors of motion pictures, not members of this association, be urged to cooperate to carry into full effect these resolutions.2
According to some welfare organizations,3 producers made no effort to comply with these standards. The industry at that time, however, was not very well organized; hence it was difficult to focus the responsibility at any one point, or to expect uniform action. During the period in which various social organizations were cooperating with or working apart from the industry on forms of voluntary censorship, several states enacted censorship statutes. Pennsylvania, which pioneered in 191 1,4 was followed in 1913 by Ohio and Kansas.5 The Ohio law declared that "only such films as are in the judgment and discretion of the Board of Censors of a moral, educational or amusing and harmless character shall be passed and approved by such a board".6
In 1915, the Supreme Court, acting on the cases of the Mutual Film Company,7 declared that "both statutes (Ohio and Kansas) are valid exercises of the police power and do not abridge public opinion". The court, speaking with reference to the Ohio statute, stated:
The argument is wrong or strained which extends the guaranties of free opinion and speech to the multitudinous shows which are advertised on the billboards of our cities. . . . The judicial sense supporting the common sense of the country is against the contention. . . . The police power is familiarly exercised in granting or withholding licenses for theatrical performances as a means of their regulation.
Following this decision of the Supreme Court, several states enacted statutes similar to those in Ohio and Kansas.
2 See Catechism on Motion Pictures in Interstate Commerce by W. S. Chase, p. 46.
3 Federal Motion Picture Council of America, Inc., Circular No. 14, April 6, 1926.
4Penn. Session Laws, 1911, p. 1067.
5 103 Ohio Laws, 1913, pp. 399-401; Kansas Laws, 1913, C. 294.
6 Ohio Constitution, Section 3.
1 Mutual Film Co. v. Ohio Industrial Commission, 236 U. S. 230; Mutual Film Co. v. Kansas, 236 U. S. 248.