Mike Thomas
Phillips Holmes
Judge Moffett
Walter Huston
Mary Thomas
Anita Page
Released by MGM
Directed by W.S. Van Dyke
Run time: 92 minutes

Proof That It’s a Pre-Code Film

  • Based on a true story, this is a film about a corrupt judge who forces women into prostitution, frames and arrests innocent people, kidnaps children from hid enemies, has thugs beat up and export foes, robs his political foes, and suppresses evidence of all of it.
  • Taxi driver Philips Holmes finds some misplaced lingerie in the back of his cab.
  • Line that wouldn’t make it today: “This judge Moffett is a pretty gay bird!”

Night Court: Innocence Punished

“You can’t overemphasize the possibilities of evil in the lower courts. If it wasn’t for the connivance’s of the magistrates in these night courts, this corruption could not exist. […] And from there, the corruption spreads in all directions, and that’s just what we need to fight. You don’t cut off a tree at the top, you cut it off at the root. And Moffett is the root. […] For the grace of God, we’ll turn this into a clean city, for clean Americans!”

There are rules for everything, including, believe it or not, a few against corruption. This may come as a surprise nowadays, but it’s not like corruption sprung up out of the ground in 2016, nor has it been true that the democratic institutions of our country have ever been impervious to the power-hungry or power-mad in any form.

The American government was hardly seen as the sterling of moral virtue in the 1930s, something that the Production Code would soon wallpaper over any films from honestly portraying. From the Teapot Dome Scandal to the Bonus Army March, it was hardly a progressive time.

Men went into office to consolidate and abuse power; Night Court, based on one true story of judiciary corruption, shows the insidious logic where a woman, answering a simple question, soon finds herself imprisoned, her child in foster care and her husband near-destitute all to satisfy the cruel whims of a corrupt judge.

Judge Moffett (Walter Huston, mustached) takes bribes and does dirty deals through the means of his nightly court sessions. He’s also fooling around with Lil (Noel Francis), which is fine until crusading Judge Osgood (Stone, mustached) threatens Moffett’s whole operation. He sends Lil off with all of his secrets in tow, but Osgood has a detective following her and watching.

Lil ends up in a little flat next to Mary (Page) and Mike (Holmes), who have a sweet little baby and a happy home life. But, boy, how that baby screams! When Noel notices Mary casually chatting with the detective, she becomes convinced that Mary is in on the plan to bring down Moffett.

Moffett turns this over in his head and decides to strike preemptively, first by planting a man in Mary’s home and making her appear to be a prostitute and then by remanding their child from Mike’s custody. These scenes are hard to watch, as these two people are cruelly manipulated without their knowledge, stripped of their joy from only a short day earlier. Their community curdles at the hint of vice, fraying this family not only from one another but from the community they had trusted.

As the structure of American society realigns against the two of them, Mary weeps, sleeplessly, in prison, and Mike is tempted to succumb to Lil’s charms. But in a nice speech, he overcomes his jealous tendencies and the easier path of simply accepting, leads him to discovering one of Moffett’s secrets and, possibly, saving his family in the process.

Night Court is a solid drama, with some of that owed to the extra breathing room for character work– this movie clocks in at a massive 93 minutes. The film effectively builds horror upon horror as we’re pulled deeper into Mary and Mike’s quicksand pit. Director W.S. Van Dyke isn’t the flashiest of directors, but when he pulls in for a closeup, the suddenness of the move is what draws you in.

It should be noted that the film’s convoluted villainous plan that can be undone by a single, simple conversation is a bit frustrating, especially as the couple’s woes get compounded. But it’s also interesting in the way that the characters have trouble confronting it; why doesn’t Mary more thoughtfully interrogate her defense attorney about his eagerness to have her plead guilty? Why does Mike not suspect the detective he hires who so obviously sneaks off to another room to warn Moffett about Mike’s leads?

Rarely do you see such a good demonstration of the truth behind systemic corruption, where our lead’s inabilities to see where the system could fail them– they always presume it’s on their side even when it’s clear that every level of it has been infected with cruelty.

The film’s finale is deeply satisfying, humbling Moffett and changing him from a cool, in-control sociopath to a ranting, pleading maniac. For a film that has constantly lurked, stalked and hunted Mary and Mike, it’s a nice to see how Mike can use something as simple as the correct application of truth to free his family and save the day. Realistic, no. But satisfying nonetheless.

Screen Capture Gallery

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Other Reviews, Trivia, and Links

  • TCMDB notes how this film is based on a real incident:

A year earlier, New York papers had been filled with stories of corrupt judge Chico Accatuna’s involvement in a prostitution ring. He would sentence innocent women to jail time on false prostitution charges, leaving them easy prey for mobsters out to recruit workers for their brothels.

  • Karen at Shadows & Satin calls this one a treat, and has lots of little details about it, including this tidbit about Francis:

The cast also included Noel Francis as Walter Huston’s chick-on-the-side. You may not recognize her name (at least, I didn’t), but I bet you’ll know her face. She was also in Smart Money (1931), Blonde Crazy (1931), and I Am a Fugitive From a Chain Gang (1932), but her film career was over by 1937. Reportedly, she later became a radio producer in San Francisco, but she died in 1959 at the age of 53.

Night Court could have been another slam bang signature pre-Code affair had Van Dyke brought it in around 70-minutes. But while the 92 minutes may be a bit much there is no denying the extra time allows for development of several of these intriguing characters, notably those played by Huston, Holmes, Page and, strangely, Noel Francis, each of whom has plenty of opportunity to shine.

  • One last note: as a parent, seeing Mary leave her baby in the crib while she walked Lil down to the corner store probably put me on edge more than any other movie I’ve seen this year. Something could happen to your baby!! AUGH.

Awards, Accolades & Availability

  • This film is available on Amazon through Warner Archive. (Just a warning: the print on this one is super soft.)

More Pre-Code to Explore

WhatIsPreCode2 FilmList

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Danny is a writer who lives with his lovely wife, adorable children, and geriatric yet yappy dog. He blogs at pre-code.com, a website dedicated to Hollywood films from 1930 to 1934, and can be found on Twitter @PreCodeDotCom.


thestarlightstudiosbcglobal.net · May 23, 2019 at 12:56 am

This is one of two 1932 M-G-M films that are only available in poor-quality prints: Prosperity and Night Court. These films are so good that you want to see them looking as good as Red-Headed Woman does.

shadowsandsatin · May 23, 2019 at 6:18 am

Loved your write-up, Danny — I had no idea this was based on a true story! Thank you so much for the mention — you’re the berries.

hwest112 · May 23, 2019 at 8:02 am

Thanks for reviewing this. I saw it recently and was also impressed. Of course, Walter Huston is always excellent.

JOHN K. CARPENTER · May 23, 2019 at 8:42 am

I have always had a special love for this film (a TRUE example) which is a Pre-Code but in my case of lecturing at my monthly Classic Films screenings a example of REALITY ! Ever wonder why viewers in the audiences weren’t horrified by these plots ? It’s because they knew that right outside the theater doors these plots were life’s realities ! Today these are banned as Politically Incorrect BUT honestly in this day of headlines being on par if not worse then these P-C plots why are our people acting so astonished at what was then BECAUSE what was then IS STILL now !
Walter Huston is always a triple threat actor in any role EVEN in “KONGO” !

Kia Julian · May 24, 2019 at 8:47 am

Walter Huston would be great reading from the phone book, but the only thing I remember from this movie is that baby being left alone in the crib, while the adults stroll off. Scary.

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