I: Research on violent video
games has not demonstrated real-world harm
Psychologist Kevin Durkin, who reviewed the research on violent
video games in 1995, reported that studies had found "either no or
minimal effects." Indeed, he added: "some very tentative evidence
indicates that aggressive game play may be cathartic (promote the
release of aggressive tensions) for some individuals." Durkin
reported in a 1999 follow-up survey that "early fears of pervasively
negative effects" from video games "are not supported"; "several
well designed studies conducted by proponents of the theory that
computer games would promote aggression in the young have found no
such effects" .
His findings were echoed by other scholars .
proponent of the causal hypothesis, however, continued to search for
evidence of harmful effects. In 2000, Craig Anderson and a colleague
reported on a lab experiment and a correlational study they had
In the experiment, they had college students play part of either a
violent or a non-violent video game, then tested them for aggression
or "aggressive cognition" by asking them to give "noise blasts" to a
game opponents or recognize "aggressive words" on a computer screen.
A somewhat larger number of the subjects who played the violent game
excerpt gave slightly longer noise blasts or recognized the words
slightly more quickly. The differences were in fractions of seconds.
In addition, it was highly questionable whether word recognition or
noise blasts demonstrated anything realistic about actual intent to
harm another person .
Nevertheless, Anderson concluded that exposure to "a graphically
violent video game increased aggressive thoughts and behavior" .
the same article, Anderson reviewed previous video game research. Of
four experiments that found "weak" support for the causal
hypothesis, he acknowledged that none had ruled out "the possibility
that key variables such as excitement, difficulty, or enjoyment
created the observed increase in aggression." Other experiments were
negative or yielded "mixed results" and "little evidence" of adverse
effect. Yet the following year, Anderson and a colleague reported on
a new "meta-analysis" that they conducted, averaging the results of
33 separate studies on violent video games. Now, they concluded that
the studies showed violent games "increase aggressive behavior in
children and young adults" .
critiqued Anderson's new calculations as well as his interpretation
of the underlying studies .
As they pointed out, if experiments with dubious results are
incorrectly interpreted as supportive of the causal hypothesis, the
resulting meta-analysis will only magnify the error.
2000, Indianapolis passed an ordinance restricting minors' access to
violent video games in arcades. The city relied on Anderson's
"aggressive word"/noise blast experiment to assert that a causal
connection had been established between violent games and aggressive
behavior. The Court of Appeals stuck down the ordinance, ruling that
Anderson did not show that "video games have ever caused anyone to
commit a violent act," or "have caused the average level of violence
to increase anywhere." The court noted that violent themes have
always been part of children's literature; to shield youngsters from
the subject "would not only be quixotic, but deforming" .
II: Media-effects research
overall has not demonstrated that violent entertainment causes
A. Most studies have
Fantasy violence has been a theme in art, literature, and
entertainment since the beginning of civilization, but attempts to
prove through science that it has adverse effects are less than a
century old. In 1928, the Payne Fund commissioned sociologists to
gather data on the effects of cinema violence through surveys and
interviews. The process took four years, and resulted in multiple
published volumes. The conclusions were guarded and equivocal, but
caution was forgotten in a one-volume summary, Our Movie Made
Children, which became a best-seller and claimed the studies had
proved harmful effects .
the 1950s, psychiatrist Fredric Wertham asserted that his informal
research with juvenile delinquents proved violent comic books to
cause crime. Wertham's methods were anecdotal; he had no control
groups; and he mistakenly relied on correlations as proof of
causation. But his assertions resonated with a public eager for
answers to concerns about crime .
subject of study was television. Soon after TV's emergence,
politicians began to stoke public anxieties about violent content.
At the same time, a new field of psychology, social learning theory,
posited that children imitate media violence. These psychologists
believed, moreover, that such effects could be measured through
laboratory experiments. Albert Bandura, leader of the social
learning school, conducted experiments demonstrating that some
children shown films of adults hitting Bobo dolls will imitate the
behavior immediately afterward .
Even though Bobo dolls are meant to be hit, and aggressive play is
far different from real-world intent to harm, Bandura announced that
he had proved adverse effects from media violence. The announcement
resonated politically, and the federal government was soon funding
The first major result of this funding
was a 1972 Surgeon General's report that noted a "preliminary and
tentative indication" of a causal link between TV violence and
real-world behavior, but cautioned that this possible effect was
"small," and only in children already predisposed to aggression
As historian Willard Rowland recounts, however, legislators
misrepresented the report's cautious conclusions, claiming that a
definitive link had been proven .
Psychologist Jonathan Freedman, who began studying media-effects
research in the early 1980s, was astounded at the disparity between
the claims being made and the actual results. In a 1984 article, he
reported that although there is a small statistical correlation
between preference for TV violence and aggressive behavior, there is
no evidence of a causal link. Likewise, he said, laboratory
experiments, which can show a short-term imitation effect, are too
artificial to offer much guidance on TV's real-world impact. And
field experiments, more realistic attempts to gauge media-violence
influence, had wholly inconclusive results .
Freedman found many instances of researchers manipulating results to
bolster their theories. A field experiment in 1973, for example,
widely cited in support the causal hypothesis, had numerous measures
of aggression, all of which failed to produce any finding of adverse
effects. Not satisfied, the researchers divided the children into
"initially high aggression" and "initially low aggression"
categories, and again compared results. Still there were no
indications of harm from viewing violent programs ("Batman" and
"Superman"). The initially high-aggression group, for example,
became somewhat less aggressive after the experiment, no matter
which programs they watched. But after more number-crunching, the
researchers found that the initially high-aggression children who
were shown violent programs "decreased less in aggressiveness" than
the initially high-aggression children who watched neutral programs.
They seized upon this one finding to claim they had found support
for the causal hypothesis .
the most widely cited research project in these years was a
"longitudinal" study – tracking correlations over time – to
determine whether early preferences for violent entertainment
correlate with aggressiveness later in life. The researchers found
no correlation between violent TV viewing at age 8 and aggressive
behavior at age 18 for two out of three measures of aggression. But
there was a correlation for boys on a third measure of aggression –
peer reports. They seized upon this finding, and claimed proof of
harm from TV violence .
also later claimed a correlation between violent TV viewing in
childhood and violent crime at age 30. Oddly, however, they did not
disclose the actual numbers of violent criminals on whom they based
their conclusions, and their published report did not mention a link
between early violent viewing and adult crime at all. Nevertheless,
one of the researchers, Rowell Huesmann, testified in 1986 before
the U.S. Senate using a bar graph purportedly showing how violent TV
causes violent crime. When, years later, author Richard Rhodes asked
for the actual numbers, Huesmann acknowledged that the correlation
shown in his dramatic bar graph was based on just three individuals
who committed violent crimes .
Huesmann went on to write a pivotal article on media
violence in the next major government report, released in 1982 .
It was an opportunity, as Rowland observes, to "provide a resurgent
call to arms" by those "disappointed in the cautious tone" of the
1972 report .
But many scholars disputed its claim that harmful effects had been
Yale professor William McGuire, for example, wrote that despite the
hype, two decades of media-effects research had found little or no
real-world behavioral impact from violent entertainment .
researchers used correlation studies rather than experiments to test
the causal hypothesis. One much-publicized study of this type found
a correlation between the introduction of television in three
countries and subsequent homicide rates. Without considering either
the level of violent content in early TV, or other, more likely,
explanations for the increased homicides, the researcher announced
that "the introduction of television in the 1950s caused a
subsequent doubling of the homicide rate" .
Many scholars disputed his claims, most notably two criminologists
who reported in 1996 that homicide rates in many countries including
the U.S. had decreased over the previous two decades despite
increases in media violence .
correlation research flatly undermined the causal hypothesis. In
1986, for example, Steven Messner reported negative correlations
between exposure to violent TV and violent crime in 281 metropolitan
areas. Messner stated: "The data consistently indicate that high
levels of exposure to violent television content are accompanied by
relatively low rates of violent crime" 
an ambitious cross-national study coordinated by Huesmann and his
colleague Leonard Eron found no significant correlations over time
between children's media violence viewing and aggressive behavior in
Australia, Finland, the Netherlands, Poland, the U.S., or Kibbutz
children in Israel. The only strong correlations were for two groups
of Israeli city dwellers. Yet in this case, as Freedman recounts,
most of the researchers "tried to put the best face on it that they
could" in the book that resulted. "They hedged, did other analyses,
and tried to make it sound as if the results supported the initial
prediction that television violence would increase aggression." The
Dutch researchers, however, did not hedge. "Their write-up came
right out and said that there was no evidence of any effect."
Huesmann and Eron refused to publish their chapter unless they
revised their conclusions .
experiments, meanwhile, found more aggressive behavior associated
with non-violent shows like "Sesame Street" and "Mr. Rogers'
Neighborhood." Joyce Sprafkin, who conducted some of these studies,
later described her reaction: "I decided to look back carefully at
the field and say, well, what have other people really found?" For
pre-school children, the field studies simply "did not support a
special significance for aggressive television" .
year, Jonathan Freedman published a thorough review of some 200
experiments or studies – all that he could locate – attempting to
test the causal hypothesis. He found that most had negative results,
even accepting as positive some experiments that used poor, almost
ridiculous, proxies for aggression. Of 87 lab experiments, 37%
supported the causal hypothesis; 22% had mixed results, and 41% were
non-supportive. After Freedman factored out experiments using "the
most doubtful measures of aggression," only 28% of the results were
supportive, 16% were mixed, and 55% were non-supportive of the
causal hypothesis .
was hardly alone. A 2000 review of media-violence research by the
Federal Trade Commission reported that no firm conclusions about
adverse effects can be drawn .
In 1994, a
federal court in New York heard expert testimony on media-effects
research. The case involved a county ordinance that barred
dissemination to minors of any "trading card" that depicts a
"heinous crime" or a "heinous criminal," and is "harmful to minors."
Expert testimony from Jonathan Freedman and Joyce Sprafkin made
clear that, contrary to popular belief, research on the effects of
media violence has yielded inconclusive results. The court held that
the county had not justified the ordinance with any evidence of harm
from "heinous crime" trading cards .
B. Occasional positive
results do not establish real-world harm
overall failure of media-effects researchers to prove harmful
effects, some studies have reported positive findings. There are a
number of reasons why these occasional positive results do not
support the hypothesis that fantasy violence has adverse real-world
reason relates to a fundamental but often-forgotten fact about
social science research. Its results are "probabilistic." That is,
the "identification of a causal relationship" through lab or field
experiments "does not entail the conclusion that the identified
cause produces the effect in all, a majority, or even a very large
proportion of cases" .
Thus, even studies that show a "statistically significant" link
between violent entertainment and aggressive behavior do not mean
that the link exists for most, or even a substantial minority of,
individuals. "Significant" in the statistical sense "does not mean
‘important.' It means simply ‘not likely to happen just by chance'"
problem with drawing real-world conclusions from quantitative
media-effects research is that both "violence" and "aggression" are
very broad concepts. Researchers have used vastly different examples
of violent content in the cartoons, film clips, or games that they
study. Generalizations about all violence (or all "graphic
violence") from these differing examples are not trustworthy, and
fail to account for the many different contexts in which works of
art or entertainment present violence.
another problem is that experimenters have not always made their
non-violent excerpts equivalent to their violent ones in respect to
other variables such as general level of interest or excitement.
Freedman gives a striking example – an early, much-cited experiment
that compared subjects' behavior after watching either an exciting
film clip of a prizefight or a soporific clip about canal boats.
Since the canal boat film was not nearly as exciting as the
prizefight film, it was probably the subjects' general arousal
level, not their imitation of violence onscreen, that accounted for
a statistical difference in their subsequent lab behavior .
"aggression" is a further problem. For one thing, not all aggression
is socially disapproved. For another, aggressive attitudes or
"cognition" are not the same as aggressive behavior. Proxies for
aggression in lab experiments range from dubious (noise blasts; Bobo
dolls; "killing" characters in a video game) to ludicrous (popping
balloons; interpreting ambiguous stories in a way that coders
consider "more hostile"; recommending a grant termination)
aggressive play, whether in a lab or in the real world, is far
different from real aggression intended to hurt another person .
Indeed, aggressive play provides a socially approved outlet for
impulses that otherwise might take dangerous forms. Thus, the
argument that the statistical link between media violence and
aggression is as strong as the link between cigarette smoking and
cancer (or other physiological analogues that are often used), even
if it were true empirically, would be meaningless, because while
scientists can measure the presence or absence of disease,
psychologists cannot measure real aggression through the proxies
used in lab experiments.
problem is the "experimenter demand" factor. Not only are behaviors
permitted and encouraged in experiments that would be disapproved
outside the lab, but subjects generally know what the researcher is
looking for. Numerous scholars have noted this problem .
III: The functions of
hypothesis has been popular within one branch of psychology. Other
scholars take more nuanced and less simplistic approaches to both
media effects and human aggression .
They look, as Professor David Buckingham puts it, at "the diverse
and active ways in which children and young people use the media for
different social and psychological purposes" .
MIT's Henry Jenkins summed up this approach when he wrote that many
young people "move nomadically across the media landscape, cobbling
together a personal mythology of symbols and stories, and investing
those appropriated materials with various personal and subcultural
meanings." Because of this wide variety of responses,
"universalizing claims are fundamentally inadequate in accounting
for media's social and cultural impact" .
The National Academy of Sciences has likewise pointed out that the
causal hypothesis is simplistic because it fails to consider either
how different individuals respond to identical stimuli, or how
different individuals' psychosocial, neurological, and hormonal
characteristics interact to produce behavior .
entertainment influence different individuals in varying ways,
depending upon their characters, intelligence, upbringing, and
social situation. For a relatively few predisposed youths, the modus
operandi of a crime depicted in a film might inspire them to
incorporate those details into a violent act .
For a far greater number, the same violent work will be relaxing,
cathartic, or simply entertaining.
describes at least four functions of violent entertainment: offering
youngsters "fantasies of empowerment," "fantasies of transgression,"
"intensification of emotional experience," and "an acknowledgment
that the world is not all sweetness and light" .
Similarly, psychologist Jeffrey Arnett, studying a correlation
between adolescents' reckless behavior and preference for violent
music, found "sensation seeking" to be the independent factor that
accounts for both the preference and the behavior. He reported that
"adolescents who like heavy metal music listen to it especially when
they are angry and that the music has the effect of calming them
down and dissipating their anger" .
childhood and adolescence have long recognized the importance of
violent fantasy play in overcoming anxieties, processing anger, and
providing outlets for aggression. Bruno Bettelheim was a pioneer in
describing these responses in the context of violent fairy tales .
As film historian Jon Lewis explains, Bettelheim understood that
children have "terrible struggles, terrible fears"; they are "small,
and fully aware that they have no power." Violent stories "offer a
safe opportunity to fantasize about having some power in a world
that otherwise seems prepared to crush them" .
scholars, eschewing artificial laboratory experiments and using
real-world research methods such as interviews and observation, have
explored why young enthusiasts are drawn to violent entertainment.
Contributors to the anthology Why We Watch report that some
children "seek out violent programming that features heroes
triumphing over villains in an effort to control their anxieties,"
and observe that historically, as real-world violence in daily life
has decreased, "representations" have "supplanted actual experience"
as a way for youngsters to cope with their fears .
Gerard Jones recently interviewed psychiatrists, pediatricians,
therapists, teachers, and parents on the attractions of fantasy
violence. "I gathered hundreds of stories of young people who had
benefitted from superhero comics, action movies, cartoons, shoot-'em-up
video games, and angry rap and rock songs," he writes. For the most
part, he found young people "using fantasies of combat in order to
feel stronger, to access their emotions, to take control of their
anxieties, [and] to calm themselves down in the face of real
danger." Jones notes that one function of play is to explore, "in a
safe and controlled context, what is impossible or too dangerous or
forbidden" in reality.
"focusing so intently on the literal," Jones says, many media
critics "overlook the emotional meaning of stories and images."
peaceful, empathetic, conscientious children are often excited by
the most aggressive entertainment. Young people who reject violence,
guns, and bigotry in every form can sift through the literal
contents of a movie, game, or song and still embrace the emotional
power at its heart. Children need to feel strong. They need to feel
powerful in the face of a scary, uncontrollable world. Superheroes,
video-game warriors, rappers, and movie gunmen are symbols of
attractions of fantasy violence are especially pertinent to video
games. In 1995, communications scholar Joel Saxe used in-depth
interviews "to assess a full range of player preferences and
interpretations related to video games." He found that gamers
express a "deep sense of thrill" in response to the "highly
exaggerated, on-screen violent fantasy play." Transgression,
rebellion, and the ability to defy the "formal rules of civility" in
a fantasy world all contributed to the appeal. "As players elaborate
the meaning of the gaming experience," Saxe says, they interpret the
fantasy play as a "healthy outlet," providing "a means of releasing
feelings of aggression." The play "is also linked to feelings of
positive accomplishment," given the competitive format of the games,
and the level of skill required .
Similarly, researchers in Denmark, using "qualitative methods such
as in-depth interviews and observations," found "competition,
challenge, and achievement" to be particular attractions of video
games. "The violent elements in computer games are attractive as
spectacular effects," and because "they prompt excitement and
thrill." They are "in line with genres known from the film
industry," such as action films and animation, and thus have
inherited violence from other media that emphasize spectacular
effects. The element of exaggeration "is fully recognized by
children." In fact, children see the violence in video games as less
anxiety-provoking than movies and television, because it is more
clearly fantastic. The children in the investigation, some as young
as five, were fully aware of the difference between reality and the
exaggerated fiction of computer games .
of video games' appeal is their communal character. Often they are
played in groups, and even when played alone, the iconography of the
games forms a bond among many youngsters. A number of authors have
described the elaborate communities associated with video games .
Saxe notes: "even though the screen fantasy play revolves around
brute violence, the actual relations among players in the immediate
play area are cooperative, if not amiable" .
who rely on lab experiments or statistical correlations fail to take
account of this social context. As psychologist Jeffrey Goldstein
explains, young people bring their entertainment choices to bear on
"questions of identity, belonging and independence." Their taste in
clothes, music, and video games "has a social purpose."
researchers look, not at isolated individuals forced to play a video
game for a few minutes as part of a laboratory experiment, but at
game players as members of social groups, we are unlikely to come to
terms with violent, or any other, entertainment .
Likewise, the Danish researchers found that "children's fascination
with violent computer games cannot be understood without considering
these social aspects. The violent elements fascinate some children,
but this fascination should not be mistaken for a fascination with
violence in the real world. On the contrary, all children in the
investigation repudiated real-life violence" .
It is true,
of course, that many aggressive youths are attracted to violent
video games. It is also true that many non-aggressive youths are
drawn to violent games. For them, the games provide fantasies of
empowerment, excitement, feelings of competence, and membership in a
community. Jones observes: "heavy gamers as a population are
overwhelmingly non-confrontational geeks" .
researcher Celia Pearce sums up the humanist understanding of
violent fantasy games: "Most of the alarmism about violence," she
writes, "is based on a profound misunderstanding about the social
and emotional function of games. Games allow people who are midway
between childhood and adulthood to engage in fantasies of power to
compensate for their own feelings of personal powerlessness. This
role-playing function is important for children of all ages" .
Gould observed that efforts to invoke science to "validate a social
preference" can distort both science and public policy; the risk is
greatest when "topics are invested with enormous social importance
but blessed with very little reliable information" .
Censorship laws based on bogus claims that science has proved harm
from violent entertainment deflect attention from the real causes of
violence and, given the positive uses of violent fantasy, may be
counterproductive. For these reasons, the lower court's reliance on
assumptions about adverse effects from violent video games should be
rejected, and the judgment below should be reversed.
Free Expression Policy Project
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National Coalition Against Censorship
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New York, NY 10001
Attorneys for Amici Curiae