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Film Friday: "Libeled Lady" (1936)

Because today is John Garfield's birthday, my initial thought was to write about one of films. However, since I wrote about one his films last week and am better acquainted with Jean Harlow, whose 105th birthday was yesterday, this week on "Film Friday" I have decided to bring what is possibly my favorite film of hers.

Theatrical release poster
Directed by Jack Conway, Libeled Lady (1936) opens when heiress Connie Allenbury (Myrna Loy) is falsely accused of breaking up a marriage and sues the New York Evening Star newspaper for $5,000,000 for libel. Warren Haggerty (Spencer Tracy), the managing editor, turns in desperation to former reporter and notorious ladies' man Bill Chandler (William Chandler) for help. His scheme is to have Bill marry Gladys Benton (Jean Harlow), Warren's long-suffering fiancé, then pursue Connie and make the charges of man-stealing that the paper made against her ring true. That way, the suit will have to be dropped.

Bill arranges to return to America from England on the same ocean liner as Connie and her father, J. B. Allenbury (Walter Connelly). He pays some men to pose as reporters and harass Connie at the dock, so that he can "rescue" her and become acquainted. On the voyage, Connie initially treats him with contempt, assuming that he is just another fortune hunter, but Bill gradually overcomes her suspicions. Warren's plan backfires, however, when Bill and Connie find themselves falling in love and marrying. Gladys and Warren learn about this and go to their hotel, only to discover that Bill has told Connie everything. Bill reveals that he had found out the day before that Gladys' Yucatan divorce from her first husband, Joe Simpson, was not valid and therefore her marriage to him was a fake. Gladys, however, says that she later got a second divorce in Reno and that she and Bill are actually man and wife. She refuses to let Bill go, but Connie makes her realize that she only fell for him because he paid the little attentions that she was not getting from Warren. When the women hears the men fighting, Gladys rushes to Warren and they reconcile. Just then, Mr. Allenbury comes in and demands an explanation, which they loudly and simultaneously give him.

Connie Allenbury: Women can't fool women about men. You don't want Bill. I know you got him now, in name anyway. But I have his love. You can't build a life on hate or marriage on spite. Marriage is too important. Mine only lasted an hour, but... I know.

In the mid-1930s, a new genre arose in American cinema based upon the old "boy meets girl" formula that satirized the traditional love story. It was called screwball comedy, "an eccentrically comic battle of the sexes, with the male generally losing," designed as escapist entertainment for Depression-era audiences. These films "embraced chaos" and incorporated "lunacy, speed, unpredictability, giddiness, drunkenness, flight, and adversarial sport." In addition, the screwball world is "upper-class and urban, people by café society types in black tie and dazzling evening dress, guzzling champagne; the narrative often involves a journey, usually to the green world of Connecticut. The screwball couple seems to have little in common and may come from different social backgrounds: eccentric, runaway heiresses mingle with journalists, professors and detectives. [...] The heroine usually has (or appears to have) more social power than the hero."

Although little has been written about the development of screwball as a genre of comedy, many experts seemed to agree that the cycle began with Frank Capra's It Happened One Night (1934), although its male character is stronger than later became typical. The enforcement of the Motion Picture Production Code in June 1934 inadvertendly made screwball comedy one of the most successful genres of its day. Instead of abandon sex as a topic, as the Code demanded, screwball comedies replaced the direct representation of sexuality with "a brilliant use of language composed largely of cleverly disguised sexual innuendo and a verbal foreplay between the sexes." Among such prime examples as My Man Godfrey (1936), The Awful Truth (1937) and Bringing Up Baby (1938), we find Libeled Lady, "a clear-cut screwball comedy" that explores many of the themes that define the genre: "identity, privacy, publicity, play and the green world."

Myrna Loy and William Powell
Based on a story by Wallace Sullivan, Libeled Lady credited three screenwriters. "In those days we felt that multiple writers are better than one," recalled producer Lawrence Weingarten. "Maurine Watkins was the playwright, George Oppenheimer [handled the] comedy, and Howard Emmett Rogers was our plot man." Before she arrived in Hollywood, Watkins, a former Chicago Tribune reporter, wrote the 1926 play Chicago, "a lurid tale of murder laced with gin, jail and jazz" that later inspired three successful Hollywood films. Beginning his career by contributing additional material to Roman Scandals (1933), Oppenheimer went on to co-write such hits as A Day at the Races (1937), starring the Marx Brothers, and I Love You Again (1940), with William Powell and Myrna Loy. Despite being widely associated with comedy, Oppenheimer also worked in dramas, notably The War Against Mrs. Hadley (1942), for which he received an Oscar nomination. Rogers' credits include Hold Your Man (1933), with Jean Harlow and Clark Gable, and Rendezvous (1935), starring Powell.

The director of Libeled Lady was Jack Conway, "a restless, red-faced Irishman who would jump to his feet at the slightest provocation and act out a scene as he wanted it played." Conway began his Hollywood career as an actor and assistant director under D. W. Griffith, working primarily in westerns. In the early 1920s, he abandoned acting to focus on directing, gaining experience at Universal Pictures before moving on to Metro-Goldwyn-Mayer in 1925. He remained there until 1948, directing some of the studio's biggest stars, including Joan Crawford, Jean Harlow, Clark Gable, Myrna Loy, William Powell and Robert Taylor. Conway's best-known film is perhaps A Tale of Two Cities (1935), a Best Picture nominee at the 8th Academy Awards.

William Powell, Myrna Loy, Jean Harlow and Spencer
 Tracy in a publicity still for Libeled Lady
Although Rosalind Russell was initially considered for the role of Connie Allenbury, MGM ultimately decided to conceive Libeled Lady as a new vehicle for Powell and Loy, whose star personae had recently been remodelled to build on the extraordinary success of The Thin Man (1934), another key example of screwball comedy. Loy believed that the film had "virtually introduced modern marriage to the screen" and their Nick and Nora Charles later became "a blueprint for a fun, companionate marriage." Libeled Lady was the second of three films Powell and Loy made together that year; the others were After the Thin Man (1936) and The Great Ziegfeld (1936). Harlow, who had also changed her screen image in the last year, and Spencer Tracy were cast in the other two lead roles. 

According to Weingarten, none of the four stars were particularly interested in appearing in Libeled Lady. He claimed that Loy "disappeared, went to Europe" when he sent her the script and that Harlow did not want the role because she was desperate "to shake her bad-girl image and to play nicer girls." Weingarten also said that "Spencer Tracy had never played comedy before and he wanted to [instead] do The Plough and the Stars [1937]," a John Ford film based on a Sean O'Casey play that would have required MGM to allow Tracy to be loaned to RKO. Weingarten asserted further that "Bill Powell played [in Libeled Lady] because it was his last picture on the contract [he had] and he wanted to get a new contract."

Myrna Loy and Spencer Tracy
Filming on Libeled Lady commenced in mid-July 1936 and proceeded extremely smoothly throughout. All four leads felt great affection for each other and "harmonized like a crackerjack barbershop quartet." Tracy, notorious for disappearing during shoots to go on benders, managed to behave himself while making Libeled Lady and Powell even gave up his old habit of hiding out in his dressing room between takes so that he could join in the fun with the rest of the cast. One of the biggest jokes on the set was a running gag Tracy played on Loy, claiming that she had broken his heart with her recent marriage to producer Arthur Hornblow, Jr. Apparently, he even set up an "I Hate Hornblow" table in the studio commissary, reserved for men who claimed to have been jilted by Loy.

Harlow relished another chance to work with her off-screen love Powell for the first time since Reckless (1935). Although she did not have much screen time with him, she would visit the set when Powell was filming his scenes with Loy. On one of these occasions, while she was waiting for Powell to finish a scene so they could go to dinner, Conway realized that he was missing an extra for a big scene. Rather than let them postpone shooting the casting office was already closed for the night Harlow decided to put on a black wig and then joined the rest of the extras, a return to the work she had done when she first entered the film industry in 1928.

Jean Harlow and William Powell
By the time Libeled Lady began production, the Production Code had been in full enforcement for two years. Since the Code adopted the Roman Catholic view that the union of man and wife is a sacred and eternal bond, Hollywood films had to handle matrimony with respect. When head censor Joseph Breen saw the first-draft script, he stormed: "Present treatment of material is, in our opinion, in violation of the Production Code. Unless changes are made, as suggested below, it will be our duty to reject a picture made from this script." Breen condemned the screenplay's "general tendency to treat the institution of marriage casually and with ridicule."

In order to move forward with the project, MGM was forced to make some major compromises and deletions. Specific lines of dialogue implying that Harlow's character had long been her boyfriend's mistress were removed; a scene in which Gladys stuffs a key into her bra was squelched; and Powell would not be permitted to spank Loy. Even after MGM made what they considered the necessary revisions, Breen was still howling that parts of the script "reflect unfavorably upon marriage and the sanctity of the home." A few weeks later, after Metro made more relatively minor changes, Libeled Lady was finally cleared for release.

Libeled Lady was huge critical and commercial success upon its release on October 9, 1936, earning $2.7 million at the box-office. Edwin Schallert of the Los Angeles Times called it "one of maddest, merriest and best of the year," while Frank S. Nugent of The New York Times described it as "thoroughly agreeable entertainment." For their part, Variety wrote: "Even though Libeled Lady goes overboard on plot and its pace snags badly in several spots, Metro has brought in a sockeroo of a comedy. It's broad farce for the most part, and the threesome consisting of William Powell, Spencer Tracy and Jean Harlow lend themselves perfectly to the task." The critic for TIME magazine also took notice of the chemistry between the main cast, raving, "the balancing is done with as much precision as if the roles had been weighed in an apothecary's scales." Libeled Lady received a nomination for Best Picture at the 9th Academy Awards in March 1937, but lost to The Great Ziegfeld, which also starred Powell and Loy.

Ten years after its release, Libeled Lady was remade by MGM under the title Easy to Wed (1946). Directed by Edward Buzzell, the film starred Van Johnson as Bill Chandler, Esther Williams as Connie Allenbury, Lucille Ball as Gladys Benton, Keenan Wynn as Warren Haggerty and Cecil Kellaway as J. B. Allenbury. Easy to Wed follows the same plot as its predecessor, but it was shot in "glorious Technicolor" and featured several musical sequences, including "Continental Polka." Upon its premiere in July 1946, Easy to Wed became one of the biggest moneymakers of the year and earned Ball the best reviews of her career.

A Companion to Film Comedy edited by Andrew Horton and Joanna E. Rapf (2016) | Hollywood Romantic Comedy: States of the Union, 1934-1965 by Kathrina Giltre (2006) | Myrna Loy: The Only Good Girl in Hollywood by Emily W. Leider (2011) | Screwball Comedy: Defining a Film Genre by Wes D. Gehring (1983) | Spencer Tracy: A Biography by James Curtis (2011) | TCMDb (Articles) | The The New York Times review | Variety review


  1. Great post on one of my favorite movies! Especially liked the part on what Screwball comedy is.


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