Though the main concern of the Hollywood Motion Picture Production Code might best be considered the regulation of sexuality and nudity on screen during the Classic Hollywood period, its restrictions on stories set in the criminal underworld are just as impactful. In the Code’s vision of the world, criminals are justly punished for their transgressions against law and morality. Likewise, the public servants of law and order — whether they be police officers, district attorneys, judges and others — are in general meant to be portrayed in a positive light. Above all, the Code seeks to enforce a vision of the world where justice is served and the law is upheld; under the heading Plot Material in the original Code written in 1930, point 7B expresses how seriously the censors took this responsibility: “Law and justice must not by the treatment they receive from criminals be made to seem wrong or ridiculous.” In other words, the American legal system must never be seen as unfair — such portrayals would undermine the public’s confidence in the moral certitude of the law. This regulation applied similarly to the individual characters within these stories. Under Plot Material, the Code singles out vigilantism in particular in section 6C: “Killings for revenge should not be justified, i.e., the hero should not take justice into his own hands in such a way as to make his killings seem justified. This does not refer to killings in self-defense.” For characters to work outside the legal system might likewise do damage to its reputation among ordinary citizens; the system must be portrayed as fair and above all, working efficiently to bring about justice — it is not the role of individuals to secure justice, but the system within which they work. The advent of film noir in the 1940s presented particular challenges for the censorship regime, as a number of the movies made in this style were set in the criminal underworld, featuring crooks looking to make a quick buck, ordinary citizens drawn into committing terrible crimes and police officers pushed to the dark edge of the night. The Code’s prohibitions against frontal assaults on the justice system were quite strong, but individual films in the noir period did their best to negotiate one of its longest-lasting flaws — police brutality. Though seemingly in direct violation of the Code’s restrictions, noir is littered with corrupted officers and other members of the justice system — crooked lawyers, unsavory judges and, yes, cops who are all too comfortable using their fists on suspects. Otto Preminger’s Where the Sidewalk Ends (1950) and Nicholas Ray’s On Dangerous Ground (1951) gesture towards the difficult conditions under which police labor while turning a critical eye on the brutally violent detectives who abuse their power. 

In many noir films, the police loom as an ever-present threat to the conniving protagonist’s criminal plots. Where the Sidewalk Ends and On Dangerous Ground are each set amidst the police department, their titles both suggesting the paths that officers walk — the authority of the officer on the beat, drawn from the combination of the uniform, a visual representation of the state and the regular patrol of a jurisdiction. The officer’s power is geographical — like traveling salesmen, they have to know the territory and the people within it. In On Dangerous Ground, the film’s central cop Jim Wilson (Robert Ryan) has been worn down by overfamiliarity with a fallen world. Like the lonely cabbie of Martin Scorsese’s Taxi Driver (1976), Wilson sees a city infested by human garbage; the voice over spoken by Travis Bickle (Robert De Niro) in Scorsese’s film wishes for “a real rain” that will “come and wash all this scum off the streets,” a sentiment no doubt shared by Wilson in Ray’s film. As he enters a dive bar to search for a lead on a suspect in the murder of a police officer, Wilson resists the pleading cries of a heroin addict complaining about feeling sick, fends off the sexual overtures of an underage prostitute, and rejects a bribe from an eager crook. His world-weariness weighs heavily on him, a burden remarked upon by his two partners, both older and seemingly on the other side of the disillusionment that has befallen Wilson. Detective Mark Dixon (Dana Andrews) in Where the Sidewalk Ends has similarly turned away from a world that has broken faith with him; haunted by the specter of a father who lived outside the law, Dixon is single-minded in his desire to get a minor gangster, Tommy Scalise (Gary Merrill), by any means necessary. Scalise is no New York kingpin; he is a petty thief who runs a gang of six, skimming profits from a floating crap game, a profile seemingly incompatible with the level of Dixon’s hatred for him. The film suggests that Dixon will easily move to a new target once Scalise is dead or behind bars, pursuing him with the same dangerous ardor that often tilts into full-blown recklessness. Wilson and Dixon are each given cautionary lectures by their respective superiors, warned about the sheer number of complaints against them for brutality. Each detective is dismissive of the possible consequences of their actions, believing (rightly, perhaps) that their abilities to “get results” will protect them from such charges ever sticking.

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Both Where the Sidewalk Ends and On Dangerous Ground were made in the early 1950s, some 15 years before the 1966 U.S. Supreme Court ruling Miranda V. Arizona, which created a sea change in the ways police were allowed to treat suspects in their custody. Though the case did not directly address issues of police brutality, the familiar Miranda refrain made ubiquitous by thousands of episodes of television producer Dick Wolf’s Law and Order franchise and its many imitators is seen as a counterweight against police using excessive force to obtain confessions from those in their custody. In the police force at the time of Preminger’s and Ray’s films, police brutality is an accepted tactic, so long as the officers do not cross the line. When one of Wilson’s partners, the 16-year veteran Pop Daly (Charles Kemper), complains of a sore shoulder, Wilson cracks “you shouldn’t try to knock out a guy with one punch.” Daly, who is more well-adjusted than the temperamental Wilson, corrects him — he sustained the injury through repetitive motion while working in his garden, a domestic role that contrasts mightily with the job he does on the city’s streets at night. Wilson believes in the necessity of police violence, taking it for granted that Daly might have injured himself while taking part in it. In Where the Sidewalk Ends, Scalise’s gang has to make a run for it from their hideout when they find out that one of their men has cracked under a police beating and has revealed their location. Dixon, the film’s egregious example of a brutal cop, has not participated in the beating — he is at the moment, the gang’s prisoner — but his fellow officers have revealed that they have no reservations about pressing a suspect physically in order to get the information they need. Both Wilson and Dixon are brutal, but their violence has resulted in little more than light reprimand. Dixon’s chief, Inspector Foley (Robert F. Simon) reads him the riot act and knocks his detective grade down to second; the scene plays like a heart-to-heart between a disappointed father and his errant son, with Foley contrasting Dixon unfavorably to the department’s straight arrow, Thomas (Karl Malden), recently made a lieutenant. Foley warns Dixon that too many more brutality complaints — there have been 12 in one month — will hamper his career, perhaps permanently. In On Dangerous Ground, Captain Brawley (Ed Begley) issues a similar warning to Wilson in a quiet conversation over breakfast. “You let yourself get out of hand,” Brawley says, informing Wilson that there is a developing legal problem — his beating of a suspect landed the man in the hospital with a ruptured bladder. In both films, the representatives of the police department’s power structure do everything they can to nurture and protect their violent officers, often gleefully trading the arrests that result from their brutal investigations for a trail of beaten suspects. Foley eagerly reinstates Dixon’s grade after Scalise is apprehended in Where the Sidewalk Ends, even boasting that he plans to recommend him for promotion — he will presumably reach the rank of lieutenant like Thomas. Brawley decides to respond to a subsequent instance of Wilson’s brutality, even after their breakfast chat, by sending Wilson out of town on a case to let the heat cool down. In both Ray’s and Preminger’s portrayals, the police department is content to moralize about its officers’ violent methods, but stops well short of meting out consequences.

The hypocrisy of the police department is especially stark in Where the Sidewalk Ends. In Dixon’s furious pursuit of Scalise, he visits one of the gangster’s associates, the aptly named Kenneth Paine (Craig Stevens), who Scalise has attempted to frame for a murder. In Paine’s apartment, the drunken suspect first mouths off to Dixon and then takes a swing at him; after a close-quarters struggle, Dixon delivers a brutal uppercut to Paine’s jaw that levels him. When Dixon kneels down, urging the man to get up, as he has no doubt done countless times before to other beaten and brutalized suspects, he is surprised to discover that Paine is dead. He has finally, at long last, found the line — too late. When the initial shock wears off, Dixon begins to work to cover his tracks, a prospect complicated when he answers the ringing phone in Paine’s apartment, only to hear his partner Paul Klein (Bert Freed) on the other end; he can no longer slip out the back and pin the crime on Scalise, but must instead concoct an elaborate scheme to dispose of the body and throw his fellow officers off his scene. He dons Paine’s overcoat and hat, quickly packs a bag, and applies a telltale bandage that had been resting on Paine’s wounded cheekbone before calling a cab bound for Penn Station. He buys a ticket out of town and then races back to Paine’s apartment, arriving just in time to stop the snooping Klein from finding the dead man in the closet — Dixon looks instead and, knowing Klein trusts him, insists it is empty. The coldness with which Dixon is able to manipulate the crime scene, aligning it with his chosen narrative, reveals the danger of a cop who knows how to tell the story the right way, allowing him to evade punishment. Dixon’s lies come easy, but his conscience begins to weigh heavily once the intrepid Lieutenant Thomas, the department’s fair-haired boy, begins to see through the ruse. Even Thomas is not imaginative enough, however, to assign guilt to Dixon, but instead tries to pin the crime on Jiggs Taylor (Tom Tully), the father of Paine’s estranged wife Morgan (Gene Tierney). As Dixon develops a fondness for Morgan, the idea of allowing her father to take the fall for his crime becomes too much to bear, and he endeavors to get Scalise, even if he has to force the gangster to murder him to do it. Preminger, who favored long takes and a highly mobile camera, uses a number of highly compact close-ups to maximize the dramatic pressure on Dixon as his guilt threatens to overwhelm him. The physical blows between Dixon and Paine, and then later between Dixon and other members of Scalise’s gang, land hard in these tight close-ups, somewhat in contrast to Classic Hollywood’s tendency to portray such close-quarters fight scenes in wider shots.  

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As Dixon, Dana Andrews demonstrates why he is one of noir’s most affecting actors. Given Dixon’s penchant for beating suspects, one might be inclined to call him a sadist — Foley as much as states it, suggesting that Dixon “gets fun out of it.” He doesn’t seem to enjoy it, however; Dixon’s violence is a product of total insecurity about who he is. His crooked father, dead trying to shoot his way out of jail, he confesses, looms large. He struggles to reconcile the inherent violence that he is convinced must be his birthright with his role as an officer of the law — each hood he beats is a reflection of himself. Every punch is really directed at a mirror. When crafting his postwar asylum thriller Shutter Island (2010), Scorsese modeled the federal marshal-turned-mental patient Teddy Daniels, played by Leonardo DiCaprio, on the characters Andrews played for Preminger — especially the wounded detective at the heart of the oneiric Laura (1944) and the razor’s edge Dixon. Daniels’s combination of romantic desire for an unattainable woman and his penchant for brutal violence are a hybrid of Andrews’s characters in these two Preminger films and are quintessential noir. In both Shutter Island and Where the Sidewalk Ends, the effects of violence are psychologically corrosive — they destroy the men who commit such brutal deeds. Though Dixon expects to die at Scalise’s hands in the movie’s climax, and writes a confession to Foley “to be opened in the event of my death,” he survives and the gangster is apprehended. Dixon, unable to live with the consequences of his actions, rejects Foley’s offer of promotion and urges him to read the letter anyway. As the Production Code dictates, Dixon’s crime is punished, and the law is upheld — however, the lingering effect of a system that tolerates, and even rewards police brutality is an overwhelming one. Such is the case with many film noirs, which technically adhere to the letter of the Code’s law in punishing criminals, but simultaneously suggest so much is rotten at the heart of the American experiment that the whole thing may be beyond saving — a far more despairing and subversive thought.

On Dangerous Ground’s Wilson does not go so far — he does not commit a murder, either intentionally or unintentionally. However, his on-screen violence seems more sadistic than Dixon’s, a fury that Ray emphasizes through a consistent, if not quite Bressonian, focus on the impact of hands throughout the film. In one moment, Wilson corners a suspect in his dingy apartment, and Ray shoots the scene hip-high, with the suspect fearfully sitting on a chair, in focus in the shot’s background, with Wilson’s clenched fist looming out of focus in the foreground. A low angle from the suspect’s point of view stares up at the ominous Wilson as he blames the victim: “You’re gonna make me crack you, aren’t you?” he says, eagerly anticipating the outcome. “Why do you make me do it? Why do you make me do it?” he shouts, his cries indistinguishable from those of a serial killer who abdicates his own responsibility for his actions. Wilson is volatile, which Ray captures stylistically throughout the film’s first half, which is set in New York City. Bernard Herrmann’s score rumbles low and then explodes like a fuse being lit before its thunderous payoff, matching Wilson’s slow-burn intensity that, when triggered, threatens to consume everyone around him. Ray also adopts a highly unconventional technique for a Hollywood film in 1951, switching briefly to a handheld camera as Wilson chases a suspect down an alley and then again in the film’s second half as he fights off a violent assault by a vengeful father. Ray’s stylistic unpredictability goes one step further than the documentary realism then becoming more common in crime films, many of which followed in the near-newsreel style of Jules Dassin’s The Naked City (1948). Though Ray does seek to provide an immersive, city-streets experience in the film’s first half, the sudden switch to handheld is less cinéma vérité than an expression of Wilson’s combustible temper.  

The film’s pastoral second half takes place in upstate New York, as Wilson is sent out of town to lend a hand in a murder investigation; a girl has been killed and the local police seem overmatched, a fact confirmed when Wilson arrives and meets the mild-mannered Sheriff Carrey (Ian Wolfe), who is struggling to contain the vigilante rage of the murdered girl’s father Brent (Ward Bond). Brent wields a scattergun and vows to murder the perpetrator when he finds him, rather than letting justice be served through traditional, official means. Though Brent initially assumes Wilson will be inclined to trials and lawyers — “city stuff,” Brent calls it — On Dangerous Ground mines dramatic irony from the reality; there is apparent compatibility between the rural father bent on revenge and the disillusioned police detective eager to mete out physical punishment. Wilson must officially counterbalance Brent’s bloodthirsty animus, but it seems clear that Wilson will likely let the man kill the suspect when they find him. Plans change when their car crashes on an icy road and they seek shelter in the home of Mary Malden (Ida Lupino), a blind woman who seems to be living alone. Ray once again emphasizes hands, but this time, it is Mary’s gentle, practical groping for familiar objects and pieces of furniture in her home — while Wilson uses his hands to punish the guilty, Mary uses hers to see. Stricken by a vulnerability he seems barely to understand, Wilson’s hands soften from clenched fists to open palms. When it becomes clear that the man he and Brent are hunting is Mary’s mentally ill brother, he even promises to her that he will not let Brent hurt him — instead of becoming the man’s executioner, he vows to become his protector. When faced with the real possibility of brutal, extralegal vigilantism in the form of the single-minded, grieving father Brent, Wilson makes a choice, deciding to pull back from the brink. Though Mary’s brother is killed in a fall while Wilson and Brent chase him, Wilson finds solace in Mary’s arms, their hands joining together without a hint of the violence he has used them to commit. Wilson, despite his sins, is not beyond redemption, even in the eyes of the restrictive Production Code.

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Noir was especially suited to tackle these kinds of live political and social issues because these films were willing to confront social problems and present a vision of the world gripped by existential dread. The aftermath of the social upheaval of the summer of 2020, a seeming culmination of outrage against an American policing system that seems to have lost all claim to its moral authority, revealed to many that these problems have long been allowed to fester — far too late, of course, for George Floyd, Breonna Taylor and the countless other victims of police brutality. Police officers who abuse their authority, as agents of the state imbued with the right to commit violence, are no less common in contemporary cinema. In fact, there may be more than ever. As in their noir predecessors, contemporary films likewise choose between punishing these cops, as in Where the Sidewalk Ends, and offering them redemption, as in On Dangerous Ground. Few 21st century movie cops have made a bigger on-screen impact than the villain of Training Day (2001), Alonzo Harris (Denzel Washington), who beats suspects, blackmails his rookie partner (Ethan Hawke) into smoking PCP before setting him up to be murdered by drug dealers, and robs a corrupt former police officer of a stash of ill-gotten money under the guise of a routine raid. He rationalizes his actions as the necessary requirements of life on the street — “a wolf,” as he sees himself — but such protestations ring hollow, mere cover for the life of a desperate criminal who needs money to pay back a gambling debt incurred to a mob of deadly gangsters. Harris is punished at the film’s end when the gangsters ride up on his car and blow him away in a fusillade of gunfire, a worthy recompense for his many sins. Far more complicated morally is the on-screen redemption of Sam Rockwell’s racist cop (also named Dixon) in Three Billboards Outside Ebbing, Missouri (2017). Rockwell’s Dixon is an overt bigot who is finally suspended from the small-town police force after he tosses a businessman out of a second-story window in broad daylight; the film’s rehabilitation of him brings him into alignment with Mildred (Frances McDormand), who seeks justice for her murdered daughter — the pair heads off together in a vigilante quest to kill the alleged perpetrator when the film ends. Dixon changes, the film would have us believe — it is a reflection of the change in times that a reprehensible character can be redeemed by agreeing to participate in a vigilante murder of a man who may not even be guilty, a far cry from the strictures of the Code. And yet, each of these films reveal a similar unresolvable tension at the heart of American society that has lingered since noir began: what do we do with cops who betray their oaths? In the face of a political system that has more or less chosen to do nothing at all, noir, both past and present, offers punishment and redemption. 

Brian Brems (@BrianBrems) is an Assistant Professor of English and Film at the College of DuPage, a large two-year institution located in the western Chicago suburbs. He has a Master’s Degree from Northern Illinois University in English with a Film & Literature concentration. He has a wife, Genna, and two dogs, Bowie and Iggy.