Paul H. Henry April 4, 1995

If for nothing else, 1994 seems destined to be remembered as the Year of O.J. The murder of football star O.J. Simpson's ex-wife Nicole Brown Simpson and her friend Ronald Goldman on Sunday, June 12, 1994 and his subsequent arrest and trial set into motion a flurry of crime coverage by the media that is almost unprecedented. Almost, because as historians have been continually reminding audiences from the day Simpson was arrested, these events in many ways parallel a set of happenings from 73 years prior: the murder trials of film star Roscoe "Fatty" Arbuckle in 1921 and 1922.

Arbuckle was one of the major stars of the silent screen when he was charged with the rape and resulting death of an obscure 25-year-old starlet named Virginia Rappe at a drunken party on Labor Day weekend in 1921. The details were shocking, the rumors more so: that Arbuckle had torn Virginia's insides with his 266-pound weight; that his drunkenness had alternately rendered him unable to perform, whereupon he angrily violated the girl with a wine bottle, or a Coke bottle, or worst of all, with a jagged piece of ice. When all was said and done, however, Arbuckle was acquitted in his third trial. He was free, but his career was over, and he died in 1933 having never regained his former popularity.

This paper will attempt to illustrate the media climate surrounding the Arbuckle-Rappe incident and depict the reaction of the news organs of the day to the unprecedented scandal.

One important reason why the Fatty Arbuckle incident was the first scandal of its kind was that Arbuckle was one of the very first "mass" celebrities. For the first time, performance was divorced from the actual presence of the actors, and a performer could be as well known in Thermopolis, Wyoming as in New York City. A brief biography will introduce Roscoe Arbuckle and place him in the context of his time and his fame.

This is a media paper, not a legal paper, and in-depth analysis of the facts of Virginia Rappe's death as brought out in testimony would probably be inappropriate. Nevertheless, it is the author's belief that any attempt to comprehend the media's approach to Arbuckle's arrest and trials would be impossible without an understanding of the events of Labor Day weekend, 1921. For this reason, a section has been devoted to laying out an abridged version of the goings-on at the St. Francis Hotel in San Francisco. Such an account is extremely difficult to construct, as contemporary news accounts and Arbuckle's biographers all give radically different versions of the truth. These different versions have been combined into an account which takes the common elements of the different stories as fact and treats the more controversial parts as theory.

In 1995, it is impossible to count all the different categories of media, but it's probably safe to assume that every last one of them has been in some way involved with reporting or analyzing the O.J. Simpson scandal. Time magazine has even established "The O.J. Files," a World Wide Web site of Simpson lore on the Internet. But in 1921, there was only one news medium worth of the name: the print media of newspapers and magazines. Radio was still experimental and a novelty, and filmed newsreels hardly posed a threat to the print media's dominance. For these reasons, analysis of the coverage of Arbuckle's scandal has been confined to the print media. Highlights of the story will be covered in chronological order, accompanied by details of the news reportage and analysis from 1921 and 1922. This paper will demonstrate how the newspapers of the time almost in unison engaged in anti-Arbuckle bias in varying degrees. A lot of space will be given over to coverage from the New York Times, which had and still has a reputation as a newspaper of record and which the author has found to be the most accessible major daily from that time.

The Times, biased though it was against Arbuckle, paled in comparison to the screaming headlines of William Randolph Hearst's newspaper empire. Hearst's role in whipping up anti-Arbuckle sentiment (as well as newspaper sales) will be explored.

Lastly, this paper will examine the minor resurgence of the Arbuckle scandal in connection with the Simpson arrest. Contemporary accounts of the incident will be discussed and compared with historical accounts and the views of history.

It is assumed that the reader is already quite conversant with the details of the O.J. Simpson case, and the reader is invited to compare the various aspects of the two cases for him or herself. The armchair media critic of today is often surprised to find that, whatever failings the media may possess today, it was probably much worse Back Then. Whether that holds true in the case of celebrity scandal is left to the reader to decide.

Roscoe Conkling Arbuckle was born on March 24, 1887 in Smith Center, Kansas. The Arbuckle family was poor, and moved to California in 1888. The young Roscoe, nicknamed "Fatty" for his weight, enjoyed success as a singer with a beautiful voice, an ironic career for the future silent star.

In 1912, Arbuckle met Mack Sennett, owner of the then-new Keystone Film Company. Sennett was enchanted by the big, graceful man, and put him to work making the kind of movies that would make both men famous: slapstick two-reelers in which custard pies were thrown back and forth like mad.[1] At Keystone, Arbuckle worked with future legends like Chester Conklin, Ben Turpin, and a young Englishman named Charlie Chaplin, who would one day put on a pair of Fatty's oversized trousers and create one of the most instantly recognizable characters of all time, the Little Tramp.[2]

Arbuckle continued to grown in popularity as one of Sennett's frantic, chaotic Keystone Kops, and soon found himself transformed into a headliner in the popular "Fatty and Mabel" series of films, in which he starred with Senett's girlfriend Mabel Normand.[3]

By the time of his defection to Famous Players-Lasky, a division of Paramount Pictures, in 1916, Arbuckle was as big a star as the enormously popular Charlie Chaplin. Paramount offered Arbuckle complete artistic control over his pictures, and created the Comique Film Corporation especially for him. Only one major movie maker would be offered complete artistic control ever again, and then only on one picture--Orson Welles, for Citizen Kane.[4]

Over the next five years, Arbuckle's popularity grew, as did the length of his pictures. By 1920, he was making seven-reel feature films and had launched the career of a young Buster Keaton. As 1921 rolled around, Roscoe's career was on a continuous upward tangent, and he was offered a 3-year deal with Paramount that would net him $1 million a year, which was unheard of in those days. It seemed, for a time, like nothing could stop him......

No one will ever know exactly what took place in Rooms 1219, 1220, and 1221 of the St. Francis hotel in San Francisco on September 5, 1921. The principals are all dead, and even today, historians and journalists disagree about Roscoe Arbuckle's role and culpability in the death of Virginia Rappe. The general consensus among those who have studied the Arbuckle trials is that he was indeed innocent of raping and murdering Virginia, but even today some accounts report the rape as uncontested fact.

It is possible to stitch together all the different stories and agree upon several details that are common to most or all of them, as well as speculate on the veracity of some of the better-known rumors that have become intrinsic parts of the Arbuckle mythos.

Roscoe Arbuckle made fully nine feature films during the first eight months of 1921, the final three of which were made simultaneously, with Arbuckle jumping from studio to studio on the Paramount lot.[5] Even during the silent era, when films were made in much less time than today, this was a tremendous workload. Arbuckle felt entitled to a little recreation time, and announced his intention to take a drive up to San Francisco on the morning of Saturday, September 3, in his custom Pierce-Arrow automobile with two friends, director Fred Fischbach and actor Lowell Sherman, to celebrate his new $3 million contract with Paramount Pictures.

Then and now, Roscoe Arbuckle had a bit of a reputation as a man who worked hard and played hard. Some of Arbuckle's contemporary defenders have gone to great lengths to refute the perception of the beloved comedian as an aggressive partier, but they seem to be in the minority. It is known that Arbuckle had gin and whiskey delivered to his suite at the St. Francis Hotel, in violation of Prohibition and the Volstead Act, as well as a Victrola and several records.[6] Thus began 48 hours of drinking, dancing, and debauchery which would in some way lead to the death of a guest and the sensational trials that were to follow.

On the following morning, Sunday, September 4, three people obtained rooms at the nearby Palace Hotel: a dress model improbably named Bambina Maude Delmont, an actors' agent named Al Semnacher, and his young client, a struggling actress who would soon become very famous, Virginia Rappe.

Virginia Rappe's story has become so distorted, by attorneys for the prosecution and the defense and by the media sources scurrying to report the latest in the Arbuckle case, that it is difficult to gain a clear understanding of who the pretty young actress was and how she came to be involved in the events that led to her death. Clearly, she was not the delicate, sexually innocent flower that Arbuckle's prosecutors described to the jury. Whether or not she was the whorish alcoholic evoked by Arbuckle's lawyers and the seedier representatives of the popular press is largely a matter of interpretation.

Virginia Rappe was born in New York in 1894 to a part-time chorus girl whom some say was also a prostitute, Mabel Rapp, and an unknown father. It is not clear when Virginia added the cosmopolitan "e" to her last name, but it was under that name that she became a successful commercial model working in Chicago department stores.[7] At the time of her death, Virginia was best known as the face pictured on the sheet music cover of "Let Me Call You Sweetheart," a popular song of the time.[8]

What was not as well known during the Arbuckle trials, and certainly not reported in the better newspapers of the day, was Virginia's reputation for licentious behavior. Between the ages of fourteen and sixteen, she is rumored to have had between three and five abortions, and may have given birth to a baby girl in 1910.[9] In 1918, Virginia won a "Best Dressed Girl in Pictures" award, though she was apparently better known within the Hollywood film colony for performances given while undressed.[10] A persistent story has Virginia giving either syphilis[11] or crab lice[12] to half of the men at the Keystone Film Company, prompting a livid Mack Sennett to ban her from the premises and have the area where she worked fumigated.

Somewhere in this time period, Virginia came to the attention of Roscoe Arbuckle, who had worked at Keystone with her fiancˇ, director Henry "Pathˇ" Lehrman. The exact circumstances of the arrival of Virginia, Maude Delmont, and Al Semnacher at Arbuckle's suite on the morning of Monday, September 5, 1921 are disputed; among the favored explanations are a phone call from Arbuckle to either Semnacher or Delmont, or a direct call to Virginia from an infatuated Arbuckle.[13] Another plausible explanation is that Ira Fortlouis, a gown salesman registered at the Palace Hotel, chanced to see the pretty actress in the lobby while on his way to visit his friend Fred Fischbach at the party, and when Arbuckle and his two friends, all three of whom were acquainted with Virginia, learned that she was in town they arranged for her and her companions to visit.[14[ At least one account, probably untrue, has the trio traveling to San Francisco with Arbuckle and his friends in his Pierce-Arrow on Saturday and rejoining them on Monday.[15]

After the arrival of the three from the Palace and two showgirls, Zey Prevon and Alice Blake, the party began hopping, at least by 1920's Hollywood standards. Guests were coming and going all morning long. Arbuckle received his guests wearing only a pair of pajama bottoms, and rumors of semi-nude dancing have circulated. Great quantities of liquor were consumed by all of the guests, which would later hinder the prosecution's efforts to try Arbuckle as they unsuccessfully tried to coax memories out of the groggy guests.

Early Monday afternoon, a drunk Virginia Rappe stumbled into the bathroom of Room 1221. It is at this point that accounts of the incident begin to vary widely. The prosecution claimed that Arbuckle was heard to say "I've been trying to get you for five years,"[16] a charge vehemently denied by Arbuckle's defenders, both then and now. Arbuckle went into the bathroom, shut the door, and was not heard from for another 15 minutes. Prosecutors claim that this is when the rape took place.

Arbuckle said later that he found Virginia stooped over the toilet vomiting and in pain. He held her head and cleaned her up, and helped her over to his bed, thinking that she would feel better once she got a chance to sleep. He then changed out of his pajama bottoms and rejoined the party.[17]

A crowd gathered around Virginia's bed when it became clear that she wasn't getting any better. At some point, the hysterical woman began to tear her clothes off, screaming that she was hurt or dying.[18] An argument developed between Arbuckle and Maude Delmont over the best way to treat the injured girl, and the intoxicated guests subjected her to bizarre treatments that may have contributed to her eventual death. Fred Fischbach filled the bathtub full of ice-cold water and immersed the nude Virginia in it, and Arbuckle placed an ice cube on Virginia's upper thigh or her vulva (this would later be transmuted into the charge that Arbuckle raped Virginia with a jagged piece of ice).[19]

None of these treatments helped calm the screaming girl appreciably, so Arbuckle carried Virginia to a vacant room down the hall. Doctors were called, and the party ended with most of the guests giving little thought to Virginia, whom they thought was merely suffering a hangover.[20]

Virginia was not taken to a hospital until Thursday, three days after collapsing. During that time, she was visited by the house detective and examined by several doctors and nurses, none of whom seemed to appreciate the seriousness of the girl's injuries. Finally, on Thursday, she was admitted to the Wakefield Sanitorium, which was not a conventional hospital but a maternity hospital and a well-known haven for well-to-do women seeking semi-legal abortions. It has been theorized that Virginia's injuries were the result of a botched abortion that she underwent before visiting the Arbuckle party.[21]

On Friday, September 9, 1921, Virginia Rappe died at the Wakefield Sanitorium. The cause of death was listed as peritonitis brought on by a rupture of the bladder that had been caused by an extreme amount of "external force."[22]

Arbuckle, who had returned to Los Angeles by that time, soon found his house besieged by reporters, who were the first people to tell the star that Virginia had died as a result of her injuries. Arbuckle soon found himself driving back to San Francisco with Paramount studio lawyer Frank Dominguez in tow. On Saturday, September 10, in San Francisco, Roscoe "Fatty" Arbuckle was charged with murder.

The first stories linking Roscoe Arbuckle with the death of Virginia Rappe began appearing on Saturday, September 11. The newspapers reported that the popular star would be taken into custody, and gave Arbuckle a chance to tell his story, which the New York Times repeated verbatim.[23]

Other newspapers were less kind to Arbuckle, utilizing carefully chosen adjectives and rushing to conclusions about facts not yet in evidence:

"A deathbed statement by beautiful Virginia Rappe, artist's model and actress, charged Roscoe (Fatty) Arbuckle, film comedian, with causing her fatal injuries, according to Miss Jean Jameson, a trained nurse, who was questioned by police tonight. Miss Rappe died from injuries received at a wild drinking party given by Arbuckle."[24]

On that Sunday, one day after Arbuckle's second arrival in San Francisco to answer police questions, the story was front page news all over the world.

Early stories on the Arbuckle case were riddled with inconsistencies and errors, a partial consequence of the lack of electronic news-gathering devices and transmission equipment which today allow the media to receive updates and corrections much faster. The New York Times, for example, reported that Virginia's stomach was removed during her autopsy,[25] when in fact the doctors removed her bladder and reproductive organs for further study.

The newspapers' propensity for minor misstatements of fact reached comical heights with their repeated attempts to spell the unusual stage name of witness Sadie Reiss, alias Zey Prevon. The young showgirl's name was variously spelled Zey Prevon[26], Zey Preven[27], Zey Pryvon[28], Zey Prevan[29], Miss Pyvron,[30] Zeb Prevost[31], and Zeh Prevost[32] in coverage of the incident and the trials. Occasionally, a newspaper would spell her name two or three different ways in a single story.

In subsequent days, the media were to report Prevon's own story, which she would later recant, as evidence favoring the prosecution.[33] Monday's stories were longer and more thoroughly researched, and were accompanied by sidebars about the film community's reaction to the arrest and the considerable anxiety of some of its members now that the bright light of public scrutiny was focusing on Hollywood's wild parties at which prohibited liquor flowed freely.[34] (Indeed, some of Arbuckle's biggest troubles at first would come not from San Francisco police but from Prohibition agents.) Papers favored their readers with woodcuts of the principals in the case, focusing especially on the comely Virginia.[35]

The preliminary hearings in front of the grand jury were covered zealously. Preliminary hearings belong to the prosecutor, who must prove to the grand jury that enough evidence exists to level indictments against the accused. Because grand jury testimony at the time was secret, the politically-motivated prosecutor, Matthew Brady, realized early on that his case was to be tried in the public eye as well as in a San Francisco courtroom. The press eagerly lapped up Brady's tales of witness tampering.

Many events came to a head Monday evening, and the papers on Tuesday, September 13, carried more Arbuckle news than on any prior day. While the grand jury hearing was proceeding in secret, the coroner, Dr. Leland (first name unreported and still unclear), was holding an inquest to determine if Virginia's death constituted murder. The coroner's inquest was not secret, and it was from the coroner's inquest that the public got its first real taste of Arbuckle's accuser, Maude Delmont.

Delmont's original statement to the police , which formed the basis for the State of California's case against Roscoe Arbuckle, was so transparently and luridly false that the prosecution never allowed Delmont to testify at any of Arbuckle's three trials. Nevertheless, she repeated her story to the coroner's jury, which the newspapers ran under headlines like "ARBUCKLE DRAGGED RAPPE GIRL TO ROOM, WOMAN TESTIFIES."[36]

Delmont had been a media darling since the first days of the scandal, and was eager to give her story to reporters, who ate up her heroic self-portrait:

"Mrs. Maud [sic] Delmont, the girl's close friend, has been since the death of the Rappe girl in a state of collapse in her room on the twelfth floor of the St. Francis under constant police surveillance. Through the untiring efforts of the police and members of the District Attorney's staff, Mrs. Delmont was induced to make a full statement of her knowledge of the case before a dozen officials.[37]

Though the New York Times referred to Delmont as Virginia's "close friend" on September 12, they reported the next day that Delmont was "not ... well acquainted with Miss Rappe."[38] The latter version appears to be closer to the truth.

Delmont's damning testimony to the coroner's jury figured prominently in news coverage on September 13, along with the federal inquiry into Arbuckle's Prohibition violation. Maude Delmont was again treated quite sympathetically by the New York Times:

"Mrs. Delmont, the chief complaining witness against Arbuckle, became hysterical in the jail elevator on the way to the bond and warrant clerk's office. She caught Captain Duncan Matheson by the sleeve.

"'Oh, please, don't make me face Arbuckle,' she moaned. "I don't ever want to lay my eyes on him again.'

"After a moment she controlled herself and gave the first flash of grim determination to go through with the matter for her dead friend's reputation.... Mrs. Delmont, after making the formal complaint, was led from the court room in a hysterical condition."[39]

(The melodramatic reference to "her dead friend's reputation" appeared in the same news story as Delmont's own admission that she and Virginia had not been particularly well acquainted.) The Times also made a great deal of Arbuckle's initial refusal to appear in arraignment court, wishing instead to be arraigned in his cell, and the Judge's indignant declaration that all men were to be treated identically in his courtroom.[40] The paper also passed on information that the $1-million-per-year star's stepmother was impoverished and working as a charwoman in San Jose.[41]

This kind of coverage from the usually-reliable Times was not altogether atypical of its approach to the case in general. One Arbuckle biographer has noticed a strong pro-prosecution bias in the newspaper's pages during the trials and the incidents leading up to it:

"The New York Times, which was to become a relentless critic not only of Arbuckle but of any person or group who tried to help him ... competed daily with the tabloids, lending authority to the attack." [42]

September 13 was also the day when the first reports of voluntary and state-mandated bans on Arbuckle's movies began to appear, news that was of course not favorable to the star.[43]

In New York, Henry "Pathe" Lehrman, Virginia's fiance, called a press conference to give his view of the situation. Lehrman had no firsthand knowledge of the goings-on in San Francisco, but pronounced Arbuckle guilty anyway. Lehrman was no longer a prominent director at the time, and as he suddenly found himself the center of worldwide attention he delivered a seething indictment of the friend whom he had once directed, which the press dutifully reported:

"Would I kill Arbuckle? Yes. I feel just as would any other man with red blood in his veins. I will not deny that I have said I would kill him if we were to meet. I hope the law will punish him and that he will receive full justice for the crime.

"Arbuckle is the result of ignorance and too much money.... There are some people who are a disgrace to the film business. They get enormous salaries and have not sufficient balance to keep right. They are the kind who resort to cocaine and opium and who participate in orgies that are of the lowest character. They should be driven out of the picture business. I am no saint, but I have never attended one of their parties. Virginia's friends were decent people, and I know she would not have associated with any one she knew to be vile."[44]

Six months later, his pain having apparently eased considerably, Henry Lehrman married his newest girlfriend, Ziegfield Follies showgirl Jocelyn Leigh.[45] He never did get around to killing Arbuckle.

During the late evening hours of Tuesday, September 13, the grand jury returned an indictment of manslaughter against Arbuckle, a crushing disappointment for prosecutor Brady, who had hoped for first-degree murder. The major event of the day had been Zey Prevon's reversal of her earlier testimony, which had originally corroborated Maude Delmont's testimony. Brady released a statement indicating his suspicion that the defense had tampered with Prevon and that he was considering perjury charges against her.[46]

In the meantime, more theatres and state film boards were banning Arbuckle's pictures, to the general approval of the New York Times, which covered deliberations by various boards of censorship around the country and reported that New York audiences were hissing his films. In Topeka, Kansas, a crowd "actually cheered when the face of the film comedian was shown on the screen", which the Times apparently considered to be an act of unmitigated gall, noting that "this action has caused several State officials to urge the censorship board to bar the pictures in Kansas."[47] In Lawrence, Kansas, Prof. William A. McKeever, who was the juvenile director of the National Presbyterian Temperance Board, urged martial law in cities until the "mad mob spirit" was removed from the movies.[48]

The spotlight was beginning to shine on Minta Durfee, Arbuckle's estranged wife, who had come to San Francisco to be with him and who declared him innocent to the press.[49] Interest was also rising in Arbuckle's boyhood in tiny Smith Center, Kansas, where residents of the town remembered him as a mischievous lad who was never given to violence[50] The Kansas City Star, which apparently had already made up its mind not to believe Arbuckle's version of events, wondered aloud if his mischievous nature had caused him to commit the crime with which he was charged:

"Does Roscoe Arbuckle's propensity for 'kidding' play a part in the predicament he finds himself in today and the charge of manslaughter he is facing? Was it only a 'kidding' note, after all, he sent to Virginia Rappe, summoning her to breakfast tete-a-tete with him in his rooms at the St. Francis hotel? Did the 'kidding' the two indulged in, as they sat together on a divan in the room, as described by their companions, have anything to do with later events of that tragic afternoon? Was Arbuckle 'kidding' her--trying to get even for a past snub she had given him--when he locked her fast in his bedroom, refusing to admit others of the party?[51]

On September 14, the coroner's jury also recommended that Arbuckle be charged with manslaughter, adding that in their opinion, Virginia's death had been caused by "some force which, from the evidence submitted, we believe was applied by one Roscoe Arbuckle."[52] Also making news was Henry Lehrman's gift of $150 to Maude Delmont, who was having trouble paying her hotel bill.[53]

On September 17, an enterprising theatre manager named F. J. Buzzetti in the small town of Thermopolis, Wyoming, decided to stage a publicity stunt. He claimed that 150 townspeople and cowboys stormed the theatre, shot up the screen, seized the Arbuckle picture that was playing there, and burned it in the street. The story made national news,[54] and when the truth was revealed four days later, the New York Times reported the correction in a much smaller story.[55]

It was at this time that the September, 1921 issue of Photoplay, a popular motion picture magazine, hit the newsstands, containing an interview of Arbuckle by Adela Rogers entitled "Love Confessions of a Fat Man." Conducted shortly before the incident in San Francisco, the light-hearted interview was pounced upon by the "yellow" papers, especially Arbuckle's peculiar line, "It is very hard to murder or be murdered by a fat man."[56]

Meanwhile, District Attorney Brady, dissatisfied with the manslaughter indictments, went ahead and pressed murder charges against the star in a third preliminary hearing called a police court. Once again, a charge of manslaughter was returned, and the trial of Roscoe Arbuckle was set to begin in November.

During the month of October, 1921, as the public waited for the trial to begin and little new information appeared from San Francisco, stories of the trial gradually migrated to the inner pages of the newspapers and often disappeared altogether for days at a time. Though public interest, by all accounts, remained high, it was apparently difficult for editors to justify using valuable space to repeat old information. For some newspapers, however, valid information was not a primary component of a good story, and Arbuckle headlines still streaked across the newspapers of a man named Hearst.

During the 1920's and beyond, William Randolph Hearst used his newspaper chains to thunder against the "liquor-and-sex orgies" of popular screen actors and the general decadence of Hollywood.[57] Hearst's piousness was based more on the principle that scandal sells newspapers than on any deeply-felt moral beliefs, as he himself was quite close to many studio barons and other important movie industry figures, and was known to throw his own lavish bacchanalias, just like Arbuckle. Hearst's hypocrisy did not go unnoticed by movie makers, and Orson Welles used it to embarrass the tycoon twenty years later in the thinly-disguised Hearst biography Citizen Kane. Welles chose to make dying newspaper magnate Charles Foster Kane's final word "Rosebud," which was Hearst's pet name for the clitoris of his mistress, actress Marion Davies.[58]

In the autumn of 1921, therefore, the logical course of action for "yellow" newspapers such as Hearst's flagship San Francisco Examiner, which had the fortuity to be published in the city where the famous incident took place, was to rail against motion picture immorality and the Violation of Young Womanhood. The portraits were clearly drawn in the pages of Hearst's publications: Virginia Rappe, the sweet, innocent virgin of America's hearts, and Roscoe "Fatty" Arbuckle, the enormous, sexually voracious lecher. Virginia's memorial service was reported for Hearst thusly, by Lannie Haynes Martin:

"FLOWERS BEDECK BIER OF 'BEST-DRESSED GIRL'

"Little Virginia Rappe, 'the best-dressed girl in the movies,' whose up-to-the-minute clothes have been the admiration and the envy of thousands, wears today the oldest known garment in the world. It is a shroud.

"Today her body lies in state, from 10 to 4 in the Strother and Dayton undertaking establishment on Hollywood Blvd. Tomorrow morning at 10:30 a simple burial service will be read by the Rev. Frank Rodenbush of St. Stephen's Church. Miss Everett Matoon and Miss Jessie Pease will render a few sweet and tender old-fashioned melodies, and then the remains of the girl whose death has shocked the nation will be placed in the Hollywood cemetery. Wrapped in her winding sheet of sheer white silk, a sheaf of dead white roses on her breast, her lips parted, showing her pearly teeth, there is still some of the old-time beauty and sweetness in her face, but the sparkle of her eyes, her chief charm, lies forever dimmed beneath her heavy lashes....

"Today hundreds will pass through this flower-bedecked chapel and view the body. In that throng will be the kindly sympathetic, the friendly acquaintance, the screen worshiper, the merely morbidly curious. Will any of these remember another dead Virginia who lay in state in the Forum of Rome? The Virginia slain by the hand of her own father to save her from the rapacious embrace of the licentious Claudius? Will any pause and recall that the death of Virginia was the means of ending the corrupt saturnalia of ancient Rome, which is said to have had no parallel until the present day. Would not this dead girl now, whose every impulse was said to have been wholesome and kindly, whose life is said to have been given to defend her honor, would she not feel that her life and death had not been in vain if those who read her story would be influenced to saner, simpler living, would see as she saw at the end how futile it is to seek gaity and pleasure which are not 'within the law.'"[59]

Among the tactics used by the Hearst papers in their crusade against Arbuckle were doctored photographs. One consisted of prison bars superimposed over an ordinary stock photo of the star. Another was a montage of Arbuckle, Virginia, and a prohibited bottle of whiskey.[60]

Years later, when Arbuckle was trying to get back into pictures, William Randolph Hearst actually gave him one of his first real post-scandal jobs directing The Red Mill, a mediocre film starring the equally mediocre Marion Davies. Silent star Aileen Pringle later recalled that on the first day of shooting at the Hearst-owned Cosmopolitan Pictures, Arbuckle went up to Hearst (the tycoon liked to hang around film shoots to keep an eye on his attractive mistress Davies and make sure the men on the set did not focus undue attention on her) and asked "Why are you giving me a job when you did everything you could to hurt me?"

Hearst's reply was to pat Arbuckle on the shoulder and say "I don't care what you did, son. All I ever wanted to do was to sell papers."[61]

On November 18, 1921, opening arguments began in the State of California v. Roscoe Arbuckle. In an interesting contrast with today, newspapers printed the names of all twelve members of the jury, along with their respective occupations (among the listed careers were "explosive expert" and "candy dealer").[62] For a newspaper to print names and identifying details about jury members even in minor trials would be unthinkable today. Indeed, the judge in Arbuckle's first trial was so unconcerned about the possibility of jury contamination that he adjourned the trial at midday on Saturday, November 19 so that jurors could attend a football game between Stanford and the University of California.[63]

Prosecutor Brady was hampered in his efforts to get Maude Delmont's charges against Arbuckle in front of the jury by Delmont's pre-trial arrest for bigamy, which would not help endear her to 1921 jurors. Brady temporarily quashed the arrest warrant in an unsuccessful attempt to salvage his witness.[64]

The trial was conducted with considerably less media fanfare than had been the incident itself and the pretrial hearings. The New York Times covered the trial on its inside pages, rather than on page one or two, and most of what was in the papers was a re-hash of discoveries and revelations that had been made in September. Then, as now, the trial was apparently viewed as somewhat anti-climactic.

The first weeks of the trial saw testimony from doctors, nurses, detectives, and the showgirls Zey Prevon and Alice Blake, all of whom essentially repeated their earlier testimony. None of it was of significant interest to editorial staffs.

Then the prosecution rested, and Arbuckle's new lawyer Gavin McNab (Frank Dominguez had been dismissed by Paramount after failing to secure an acquittal in the pretrial hearings) rose to begin presenting his defense. McNab called the hotel detective, a maid, and more medical personnel who had treated Virginia shortly before her death. Other defense witnesses testified that Virginia had a history of tearing off her clothes and screaming after having too much to drink.[65]

The most thoroughly covered part of the trial was when Arbuckle went to the stand in his own defense on November 28. The Times reprinted large parts of his testimony verbatim.[66]

Matthew Brady went once again to the court of public opinion, denouncing in the press what he called "perjury and witness-bribing" from the defense and vowing to release a notorious organized crime gang from San Quentin prison if Arbuckle was acquitted. Gavin McNab's bemused response was to suggest that Brady begin preparing for the gang's release immediately, and to reveal for the benefit of the public that Alice Blake and Zey Prevon had been at one time confined at the home of a prosecution team member's mother to try and elicit testimony that was more friendly to the prosecution. Hearst's papers printed Brady's statement, but not McNab's response.[67]

Assistant DA's Leo Friedman and Milton U'Ren delivered the state's closing arguments on December 2. U'Ren appealed to Biblical sensibilities in the jury and the public, recalling the Feast of Belshazzar in Daniel, chapter 5. U'Ren likened Arbuckle to the imperious king, sitting on his throne and pouring wine.[68]

In Gavin McNab's closing argument, the charismatic Scotsman hammered away repeatedly at the prosecution's failure to put Maude Delmont on the stand, suggesting that Brady had no faith in her ability to give convincing testimony and asking the jury to acquit Arbuckle in the absence of the chief complaining witness against him.69 Delmont's absence and McNab's references to it were not highlighted in press accounts of the closing arguments.[70]

On December 4, Judge Louderback discharged the jury after they were unable to come to a decision. The final count was ten in favor of acquittal, two in favor of conviction.71 A new trial date was set to start on January 9, 1922.

Interest once again waned until the second trial began. Maude Delmont made news again in a minor way upon her arrest for bigamy.[72]

Arbuckle's second trial didn't carry many surprises for the press to report. An exciting moment came early on when perennial press favorite Zey Prevon testified to having been influenced by Matthew Brady and Milton U'Ren to declare that Virginia said "He [Arbuckle] hurt me.":

"I told Mr. U'Ren that I didn't remember Virginia saying anything of the kind, but that if he said that she had said it, it was all right."[73]

The media's continued attention to the young, exotically-named dancer may be at least partially explained by a statement from Minta Durfee Arbuckle:

"Prevon and [Alice] Blake were the most potentially damaging witnesses Brady had. Zey was a very pretty blonde, on the voluptuous side, who had come from a fine family. She had a bad marriage and a child out of wedlock, which in those days was not the thing to do."[74]

Brady had essentially lost the testimony of Alice Blake and Zey Prevon, but his case was helped when McNab chose not to call Arbuckle back to the stand after the prosecution had all his testimony from the first trial read into the record. McNab also decided not to give a closing argument at all, citing his desire not to bore the jury.[75] On January 28, once again, the jury failed to come to a decision, but this time they were ten to two in favor of conviction.

Brady doggedly pursued a third trial, to be held in March 1922. Coverage again largely dried up between the trials. A distressed Zey Prevon once again provided grist for news copy when she escaped from police by lowering a rope from her fourth-floor hotel room window in New Orleans and fleeing, apparently to Cuba, to avoid the rigor of further testimony.[76]

Maude Delmont, meanwhile, finding her services of little or no use to Matthew Brady, took her story on the road. She was booked in a one-woman show at the Empress Theater in Kansas City, Missouri to tell her version of events. Handbills called her "THE WOMAN WHO SIGNED THE MURDER CHARGE AGAINST ARBUCKLE" and held the accused bigamist to be a defender of morality:

"Mrs. Delmont will tell of the famous Arbuckle-Rappe murder case. She will rip wide the screen which hides Hollywood and the movie colony. Her's [sic] is a story for Every Father and Mother, every Young Man and Young Woman in Kansas City."[77]

Maude Delmont would never testify at any of Arbuckle's three trials, but she found a voice in the court of public opinion.

At the third trial, which began on March 13, 1922, Gavin McNab had learned a lesson from the mistakes he had made during the last trial. This time, the attorney put a lot of effort into countering the prosecution's claims that Virginia Rappe was a virgin or at least chaste. He produced Josephine Roth, owner of what passed for an abortion clinic at the time, to testify that Virginia had been her patient five times: four for abortions, and one to give birth to a baby boy when she was fourteen years old. McNab's strategy was to talk about the Mack Sennett fumigation incident, and to speak of the Chicago sculptor who had once been Virginia's lover and who later committed suicide. In a dramatic moment, he introduced into evidence Virginia's injured bladder in a glass jar, to gasps and groans from the gallery.[78] The newspapers, squeamish and more than a little prudish, published little of this.

After closing arguments much like the previous ones, the case went once again to the jury. On April 12, 1922, after a mere six minutes of deliberation, the jury acquitted Roscoe Arbuckle. Five of those minutes had been spent writing this statement:

"Acquittal is not enough for Roscoe Arbuckle. We feel that a great injustice has been done him. We feel also that it was our only plain duty to give him this exoneration. There was not the slightest proof adduced to connect him in any way with the commission of a crime.

"He was manly throughout the case and told a straightforward story on the witness stand, which we all believed.

"The happening at the hotel was an unfortunate affair for which Arbuckle, so the evidence shows, was in no way responsible.

"We wish him success and hope that the American people will take the judgment of fourteen men and women who have sat listening for thirty-one days to the evidence that Roscoe Arbuckle is entirely innocent and free from all blame."[79]

Soon after his release, however, Arbuckle was to run afoul of another judge, one who needed no evidence and no attorneys and whose jury was the public. On April 18, 1922, Will Hays banned Fatty from the screen.

William Harrison Hays was a 42-year-old Republican politician from Indiana who resembled, in appearance and in behavior, nothing so much as a large weasel. A former Postmaster General in President Warren Harding's Cabinet, Hays was selected by the major studio bosses, Paramount's Adolph Zukor among them, to clean up Hollywood.

In 1922, the film colony was reeling from another very public embarrassment. On February 1, between Arbuckle's second and third trials, important Paramount director William Desmond Taylor was murdered by an unknown assailant, whereupon the nation learned of Taylor's involvement in drugs, witchcraft, and women. Taylor was having simultaneous affairs with at least four women, among them Mack Sennett's flame Mabel Normand, Mary Miles Minter--Paramount's demure answer to "America's Sweetheart" Mary Pickford--and Charlotte Selby, Mary Miles Minter's mother! Police also discovered a collection of photographs showing Taylor making love to a number of women, and a closet containing hundreds of pairs of panties, each labeled with the name of its former owner and the date of its acquisition by Taylor.[80] It is probably safe to say that revelations of this sort about a famous Hollywood figure would be unnerving to a lot of people in 1995. In 1922, it was like a bomb dropped on America. The press and the pulpits seized on the Arbuckle and Taylor cases and demanded immediate government regulation of film to weed out the immorality that they said was poisoning the country. The nervous studio moguls decided to head off government regulation by appointing their own ubercensor, Will Hays.

In 1934, Hays would set up the Hays Office, through which all motion pictures had to pass in order to have a hope of playing on a major screen somewhere. The Hays Office, which was the precursor to the Motion Picture Association of America that rates films today, would have specific guidelines about the presentation (or non-presentation) of such things as drugs, crime, sex, homosexuality, "vulgarity", nudity, religion, and patriotism, and certain words or deeds would be banned altogether in any film.81 In 1922, however, Hays was in his first year on the job at the newly-formed Motion Picture Producers and Distributors of America, Inc., and was charged merely with the mandate to clean up the movies. So it was that Hays, faced with bad press from William Randolph Hearst and constant harangues from ministers and women's clubs, dropped the axe on Roscoe Arbuckle. Despite being found innocent, Arbuckle was to be banned from pictures for living a life of booze, women, and dancing that ran contrary to the MPPDA's guidelines for upright living.[82]

But his lifetime ban was to be short-lived. On December 22, Hays lifted the ban on Arbuckle, to howls of disapproval from the nation's newspapers. The editorial in the New York Times was typical:

"Sometimes Christian charity comes too high. Arbuckle was a scapegoat; and the only thing to do with a scapegoat, if you must have one, is to chase him off into the wilderness and never let him come back."[83]

Hays' true motivation for lifting the ban will likely never be known. Some suggest that Adolph Zukor, who may have nervously suggested the ban to Hays in the first place,[84] leaned on him after receiving bagsful of mail supporting the film star's return. Or Hays could have truly felt forgiving, in the spirit of Christmas. Perversely, Hays himself, who passed judgment on a man who had been judged innocent of all crime by a jury of his peers, later saw himself as Arbuckle's persecuted savior. Hays wrote in his memoirs:

"From Providence, Rhode Island, to Seattle, I was attacked as a promoter of Arbuckle and a condoner of his previous dissipations. Many newspapers called for my resignation or ignominious dismissal. At best, these critics termed me a sentimentalist who had been duped by the all-grasping producers!"[85]

The New York Times continued its criticism of Arbuckle on into the early months of 1923, joined by the Pittsburgh Gazette Times, the St. Paul Pioneer Press, and the Chicago Post, among others. In the eyes of these papers, Arbuckle "jeopardized the morals and mental integrity of millions of impressionable young persons." Outlook magazine went so far as to suggest that the formerly-beloved comedian's "name and pictured face are odious to decent theatergoers....There is something revolting and abhorrent in holding this man up again as an amusing, even if vulgarly farcical, comedian."[86]

Not all newspapers opposed the lifting of the ban. Hays' decision was supported by the Denver Times, the Springfield Union, the Toledo Blade, and the Atlanta Constitution, among others. The prevailing attitude among these papers, however, was not that Arbuckle was innocent and ought not to be persecuted, but that good Christians had a duty to forgive the sinner.[87]

The ban had been lifted, but Arbuckle did not exactly make a triumphant return to the screen. Unable to find work under his own name, Arbuckle assumed the first and middle names of his father and directed pictures under the name of William Goodrich (or, as his good friend Buster Keaton jokingly suggested, "Will B. Good").[88]

The Goodrich comedies were mostly custard-pie two-reelers of the kind that were at that time going out of fashion, produced by obscure studios such as Educational. In the late '20s and early '30s, he was directing more full-length pictures and working with bigger stars like Buster Keaton and Louise Brooks, but what he really wanted was to be acting again. He tried to fulfill this desire by buying a nightclub and touring the vaudeville circuit.

Finally, beginning in 1932, Roscoe Arbuckle once again began performing in pictures, but it turned out to be too late. He died of a heart attack on June 29, 1933 at the age of 46, almost 11 years after his tragic starring role in the trial of the century.

Interest in Roscoe Arbuckle's trials once again rose more than 70 years later, after the arrest of O.J. Simpson and the start of yet another Trial of the Century. Seven decades of hindsight has done little to clear up the mysteries and controversies surrounding the incident, and the media today is as divided as ever as to Arbuckle's guilt.

Stories about Arbuckle and his similarity to Simpson began appearing soon after the June, 1994 murder of Ronald Goldman and Nicole Brown Simpson. In an ironic twist of fate, one of the first newspapers to carry an Arbuckle story after the 1994 murders was the Hearst Corporation's very own San Francisco Examiner, which spun a tale of pity for the disgraced comedian of the 1920s. (The Examiner's own role in Arbuckle's downfall was not mentioned in the article.)[89]

Details and conclusions about the incident and the rumors are as sketchy as ever. The usually reliable Newsweek magazine, in a startling lapse of judgment, offered as fact a version of events that runs counter to that of most contemporary news accounts and almost all historians:

"During the revelry Arbuckle seized Rappe and escorted her to another room from which guests later heard hysterical screams and Rappe crying, 'I'm dying. He's killing me.' Arbuckle then walked out giggling, wearing Rappe's hat. 'She's acting it up,' he said. 'She's always been a lousy actress.' He also threatened to throw her out the 12th-story window unless she stopped moaning. But Rappe wasn't acting. Arbuckle had told others he had jammed a large, jagged piece of ice into her vagina. Three days later she died from a ruptured bladder, having been literally raped to death."[90]

Newsweek's story is atypical, but other modern accounts hardly speak with one voice. The alleged dildo becomes a champagne bottle in one story, a Coke bottle in another, a piece of ice in the next. Maude Delmont is sometimes accused of being a madam hired by Arbuckle to supply girls for the party, one of whom was Virginia Rappe.[91] On one thing, however, nearly all accounts agree: the coverage of the Arbuckle incident, especially by the presses of Hearst and Pulitzer, make today's O.J.-obsessed tabloids and TV shows look like pikers:

"Arbuckle was arrested in Los Angeles on Saturday, the day after Rappe died. The three-inch-high headline in the Los Angeles Examiner the next day screamed, 'Arbuckle Held for Murder!'...

"The press, while generally admitting that Arbuckle's story was the most consistent of any of the witnesses, had a field day through the whole process. A selection of headlines tells the story: 'Raper Dances While Victim Dies,' 'Roscoe Arbuckle Sought in Hotel Orgy Death.'...

"Papers printed extra editions to cover every development. One publisher who really cashed in on the Arbuckle case was press baron William Randolph Hearst, whose San Francisco and Los Angeles papers published as many as eight extras a day at the height of the furor."[92]

It's easy to criticize the media of the 1920s for persecuting a man who in retrospect seems to have been innocent, but it was just as inappropriate by today's standards to have ganged up on a man who was innocent until proven guilty in the eyes of the law. William Randolph Hearst notwithstanding, the newspapers of the period were on the track to more objective, less sensational reporting when they were sidetracked by a scandal that was too delicious to ignore.

This is not to suggest that all coverage of the incident was inappropriate, unimportant though it was when compared to news from London or Tokyo or from San Antonio, which was undergoing severe flooding at the time. Indeed, when one considers the scope of the happenings--a major film star, a hero to children, accused of murder in the midst of sexual violence--it is difficult to suggest that the American media should have just ignored them.

A final note on O.J. cynicism: Hearst's alleged comment to Arbuckle about just wanting to sell papers was more telling than he realized. Hearst did sell papers; in fact, he sold quite a few of them. The public's appetite for Arbuckle news was insatiable. It would have been close to impossible to give the public everything they wanted. One feels compelled to remember this when confronted by modern-day folks who complain about the way O.J. has taken over the news. O.J. sells papers too. The public's appetite for scandal, then as now, seems to be one of the few constants in the universe.

N O T E S [1] Oderman, Stuart. Roscoe "Fatty" Arbuckle: A Biography Of the Silent Film Comedian, 1887-1933 (Jefferson, N.C.: McFarland & Company, 1994), p. 43.

[2] Ibid, p. 54.

[3] Ibid, pp. 48-50.

[4] Yallop, David. The Day the Laughter Stopped: the True Story Of Fatty Arbuckle (New York: St. Martin's Press), pp. 61-62.

[5] Yallop, pp. 100-101.

[6] Oderman, p. 152.

[7] Yallop, p. 109.

[8] Oderman, p. 152.

[9] Oderman, p. 175; Yallop, p. 109.

[10] Yallop, p. 110.

[11] Oderman, p. 152.

[12] Anger, Kenneth. Hollywood Babylon (New York: Dell Publishing, 1981), p. 29.

[13] Oderman, p. 153.

[14] Yallop, p. 108.

[15] Anger, p. 33.

[16] Oderman, p. 153.

[17] Oderman, p. 154; Yallop, pp. 113-114.

[18] Yallop, p. 114.

[19] Oderman, p. 154; Yallop, pp. 115-116.

[20] Oderman, pp. 154-155; Yallop, p. 116.

[21] Oderman, p. 175.

[22] Ibid, p. 156.

[23] "Roscoe Arbuckle Faces an Inquiry On Woman's Death," The New York Times September 11, 1921, p. 1.

[24] "Put Blame On Arbuckle," The Kansas City Star, September 11, 1921, p. 1.

[25] "Roscoe Arbuckle Faces an Inquiry On Woman's Death," The New York Times September 11, 1921, p. 1.

[26] Ibid.

[27] "Arbuckle Is Jailed On Murder Charge In Woman's Death," The New York Times, September 12, 1921, p. 1.

[28] "See Arbuckle Plot," Kansas City Star, September 13, 1921, pp. 1-2.

[29] "Arbuckle Indicted for Manslaughter in Actress' Death," The New York Times, September 14, 1921, p. 1.

[30] Ibid.

[31] "Zeb Prevost Tells Of Arbuckle's Party," The New York Times, November 22, 1921, p. 21.

[32] "Arguments Begin In Arbuckle Trial," The New York Times, December 2, 1921, p. 18.

[33] The New York Times, September 12, 1921, p. 1

[34] "Movie Capital Is Split," Kansas City Star, September 12, 1921, p. 2.

[35] "See Arbuckle Plot," Kansas City Star, September 13, 1921, pp. 1-2.

[36] The New York Times, September 13, 1921.

[37] "Arbuckle Is Jailed On Murder Charge," The New York Times, September 12, 1921, p. 3.

[38] "Arbuckle Dragged Rappe Girl To Room, Woman Testifies," The New York Times, September 13, 1921, p. 1.

[39] Ibid.

[40] Ibid.

[41] "Stepmother a Charwoman," The New York Times, September 13, 1921, p. 2.

[42] Yallop, p. 181.

[43] "Many Theatres Ban Arbuckle Pictures," The New York Times, September 13, 1921, p. 2.

[44] "Miss Rappe's Fiancˇ Threatens Vengeance", The New York Times, September 13, 1921, p. 2.

[45] Oderman, p. 157.

[46] "Arbuckle Indicted for Manslaughter in Actress' Death," The New York Times, September 14, 1921, p. 8.

[47] "600 Theatres Here Exclude Arbuckle," The New York Times, September 14, 1921, p. 8.

[48] "Would Close All Movies," The New York Times, September 14, 1921, p. 8.

[49] "Arbuckle Innocent, Declares His Wife," The New York Times, September 14, 1921, p. 8.

[50] Remember Arbuckle As Mischievous Lad," The New York Times, September 14, 1921, p. 8.

[51] "Because He Was Roscoe," The Kansas City Star, September 14, 1921. p. 2.

[52] "Arbuckle Accused of Manslaughter By Coroner's Jury," The New York Times, September 15, 1921, p. 1.

[53] "Lehrman Sends $150 To Help Mrs. Delmont," The New York Times, September 15, 1921, p. 3.

[54] "Shoot Up and Burn 'Fatty' Arbuckle Film," The New York Times, September 18, 1921, p. 9.

[55] "Arbuckle Film Not Burned," The New York Times, September 22, 1921, p. 8.

[56] Rogers, Adela. "Love Confessions Of a Fat Man." Photoplay, September 1921, p. 16.

[57] Swanberg, W. A. Citizen Hearst (New York: Charles Scribner's Sons, 1961), p. 343.

[58] Gardner, Gerald. The Censorship Papers: Movie Censorship Letters from the Hays Office, 1934-1968 (New York: Dodd, Mead & Company, 1987), p. 143.

[59] Yallop, pp. 190-191.

[60] Ibid, p. 114.

[61] Oderman, p. 205.

[62] "Five Women Seated On Arbuckle Jury," The New York Times, November 19, 1921, p. 6.

[63] Yallop, p. 211.

[64] Ibid, pp. 209-210.

[65] New York Times, November 26, 1921, p. 11.

[66] "Arbuckle Relates His Story To the Jury, The New York Times, November 29, 1921, p. 5.

[67] Yallop, p. 231.

[68] "Arbuckle Jury Locked Up For Night After Failing To Reach a Verdict In Seven Hours," The New York Times, December 2, 1921, p. 1.

[69] Oderman, p. 185.

[70] "Arbuckle Jury Locked Up For Night After Failing To Reach a Verdict In Seven Hours," The New York Times, December 2, 1921, p. 1.

[71] "Judge Dismisses Arbuckle Jury, The New York Times, December 5, 1921, p. 1.

[72] The New York Times, December 18, 1921 p. 10.

[73] "Arbuckle Witness Fails Prosecutor," The New York Times, January 20, 1922, p. 6.

[74] Oderman, p. 187.

[75] Yallop, p. 247-248.

[76] "Waited for Zey Prevon," The New York Times, February 14, 1922, p. 9.

[77] Yallop, p. 251.

[78] Oderman, p. 192.

[79] Ibid.

[80] Yallop, pp. 249-250; Anger, pp. 47-60.

[81] Gardner, pp. 207-214.

[82] Oderman, p. 196.

[83] "Hays and Arbuckle," The New York Times, December 22, 1922, p. 24.

[84] Yallop, pp. 159-160.

[85] Hays, Will H. Memoirs (New York: Doubleday, 1955), p. 361.

[86] Yallop, p. 271.

[87] Hays, p. 362; Yallop, p. 272.

[88] Yallop, p. 274.

[89] Kaufman, Gary. "Chaplin Era Was Aghast When One Of Its Big Stars Fell As Far; Before Rape Trial, Fatty Arbuckle Was Celebrated Like O.J.," San Francisco Examiner, June 19, 1994, p. A-15.

[90] Kirkpatrick, Curry. "Tales of Celebrity Babylon," Newsweek, June 27, 1994, p. 26.

[91] "OJ. Isn't First Star Accused Of Murder: Silent Star Fatty Arbuckle Was Ruined By Accusations," Charleston Daily Mail, July 4, 1994, p. 5B.

[92] Epstein, Edward. "Reel Trouble," San Francisco Chronicle, January 8, 1995, Sec. 3, p. 1.