Mutual Film Corp. v. Industrial Commission of Ohio

Mutual Film Corporation v. Industrial Commission of Ohio, 236 U.S. 230 (1915), was a landmark decision of the US Supreme Court ruling by a 9–0 vote that the free speech protection of the Ohio Constitution, which was substantially similar to the First Amendment of the United States Constitution, did not extend to motion pictures.

[citation needed] The plaintiff, Mutual Film Corporation, was a movie distributor and sought an injunction against the Board.

Justice McKenna, writing for the Court stated: ... the exhibition of moving pictures is a business, pure and simple, originated and conducted for profit ... not to be regarded, nor intended to be regarded by the Ohio Constitution, we think, as part of the press of the country, or as organs of public opinion.

The Court added that it would be equally unreasonable to grant free speech protection to the theater or the circus and noted that in many prior cases regarding government licensure of theatrical performances, the issue of freedom of opinion had not been raised.

The Production Code was loosened in the 1950s and 1960s and was eventually abandoned, in favor of the MPAA film rating system in 1968.