In 1956 New York State banned a nudist colony documentary entitled The Garden of Eden. On appeal however, the courts ruled that nudity in and of itself was not obscene. Independent film makers were becoming bolder and films like Russ Meyer's
Mr. Tease and His Playthings (1959) began to appear. In main stream Hollywood, little changed but European films continued to evolve.
Victim (1961) with
Dirk Bogarde dealt with homosexuality in a serious way and was the first film where a man said 'I love you' to another man. Other European films like
The Sweet Life (1960) and those of the the French New Wave directors continued to explore new themes.
The Pawnbroker (1964) by director
Sidney Lumet was the first Hollywood production to get a seal of approval that was in direct violation of the code. With the closure of the Legion of Decency 1965, a new MPAA production code was introduced but it too was eventually scrapped in 1968 in favor of a film eating system. A new generation of filmmakers in the late sixties however continued to push the limits of permissiveness.
—garykmcd