Nude Scenes That Got The Actors In Trouble In Real Life

The following article contains references to sexual assault.

To bare or not to bare? In Hollywood, that has always been a fraught question. Every era of moviemaking has had its share of controversies surrounding nudity on screen, whether it's Josephine McKim swimming in the buff for 1934's "Tarzan and His Mate" or Sharon Stone crossing her legs nearly 60 years later in "Basic Instinct." Even in 2023, much of the online discourse around Christopher Nolan's hit biopic "Oppenheimer" concerned a pair of intimate scenes featuring stars Cillian Murphy and Florence Pugh as a new generation debated the artistic merit of nude scenes in general and the question of how much of an actor an audience really needs to see.

In the middle decades of the 20th century, of course, the so-called "Hays Code" forbade any explicit nudity or sexual content (among a host of other moralistic guidelines). But even after the code was replaced by the Motion Picture Association of America's rating system, there were social and economic forces to consider. The MPA has long held sex to a more stringent standard than violence. A single nude scene in a film could mean the difference between a PG-13 and an R rating or an R and an NC-17 movie. 

Beyond the capriciousness of the ratings board, though, some nude scenes over the years have caused personal, professional, and even legal headaches for the actors and directors who made them. Let's take a look at some of the most troublesome nude scenes in film, on television, and even on stage.

Much of what we think of as the "Golden Age of Hollywood" was produced under the watchful eye of the Motion Picture Production Code, better known as simply the Hays Code, after its architect, former postmaster general Will Hays. The code — self-imposed by Hollywood to avoid federal censorship — placed strict limitations on nudity, sex, violence, profanity, and even moral ambiguity on screen. But by the early 1960s, the code had lost much of its authority, and in 1963, the modern era of Hollywood nude scenes began with the cruise ship comedy "Promises! Promises!" starring Jayne Mansfield.

"You read about her in Playboy Magazine...Now see all of Jayne Mansfield!" the film's poster exclaimed, and sure enough, Mansfield is topless within the first five minutes. After spending the 1950s in hits like "Will Success Spoil Rock Hunter?" and "The Girl Can't Help It," her film career had largely run aground in the new decade. "Promises! Promises!" — and the presumed controversy over its nude scenes — has been interpreted by many as an attempt to regain the spotlight. But critics, by and large, weren't fooled, and most American audiences literally couldn't see what the big fuss was about, as Mansfield's topless scenes were excised by the same regional censorship boards that the Hays Code was set up to avoid.

Director Franco Zeffirelli's 1968 film version of "Romeo and Juliet" has been a perennial favorite for decades, despite a bedroom scene featuring stars Leonard Whiting and Olivia Hussey in the nude. Like Baz Luhrmann's MTV-addled adaptation a generation later, Zeffirelli uses Shakespeare's text and themes to reflect his own era, exploring teenage rebellion and free love with the help of his young — extremely young — cast. Whiting was 16 years old at the time of filming. Hussey, a stage actress making her film debut, was just 15. The film was a major hit, rescuing Paramount Pictures from financial ruin and transforming Zeffirelli into an international auteur. For their trouble, Hussey and Whiting were given $3,000 apiece and years of trauma.

An exhaustive Vulture article from September 2023 details the way the tyrannical Zeffirelli coerced Hussey and Whiting to film the bedroom scene nude. The experience of being in the film and the year-long promotional tour that followed left Hussey with an eating disorder and agoraphobia, but for years she defended the film on its artistic merits and the love that audiences around the world still have for it. Her thinking changed, however, in 2018, when she discovered never-before-scene photos of her and Whiting nude, taken during filming on what was supposed to be a closed set. In January 2023, the two actors filed a lawsuit against Paramount, alleging abuse and distribution of child pornography.

Actors rarely face legal consequences for appearing nude on screen. Film sets are, as a rule, not public spaces, the scenes may have been filmed months or even years before being exhibited publicly, and law enforcement is more likely to target filmmakers and distributors than the actors themselves (see "Cannibal Holocaust" below). But actors performing nude on stage are more exposed, so to speak. Take the 1969 Off-Off-Broadway production of "Che!" — an absurdist political drama by the late Trinidadian writer Lennox Raphael. Depicting the final days of the life of Che Guevara, the play used nudity and simulated sex scenes to symbolize the United States' imperial activities in Latin America. The NYPD shut it down within a week of its opening, arresting Raphael, producer Ed Wode, the five-person acting ensemble, and the play's lighting operator on charges of obscenity, sodomy, and conspiracy.

The trial of the so-called "'Che!' Eight" stretched on for nearly a year. The question at hand was not whether the cast had performed nude in sexually provocative positions — they clearly had — but rather if the play itself had enough "redeeming social value" to justify the explicitness. New York Times theatre critic Clive Barnes testified for the defense, along with playwright Israel Horowitz and cartoonist Jules Feiffer. In the end, though, all eight defendants were convicted of obscenity (the sodomy and conspiracy charges were dropped). Raphael, Wode, and lead actor Larry J. Bercowitz were given 60 days in jail, while the remaining five were discharged without further penalty.

As the Hays Code was finally put to rest at the end of the 1960s, a new generation of filmmakers rose to meet the moment. Directors like Brian De Palma, Hal Ashby, and Robert Altman filled the coming decade with adult dramas (and occasional comedies) that pushed the envelope in ways that would have been unthinkable just a few years earlier. One of the most explicit and controversial films of the era came not from a homegrown "New Hollywood" auteur, but from an Italian upstart. Bernardo Bertolucci's 1972 drama "Last Tango in Paris" stars Marlon Brando as Paul, an American expat who channels his grief over his wife's suicide into an increasingly destructive affair with Jeanne (Maria Schneider), a Parisian woman half his age. Paul quickly becomes abusive, leading to a violent finale.

One particular rape scene was notorious in 1972 and has only grown more disturbing in the following decades as more information about the making of the film has come to light. Schneider, who died in 2011, alleged that the scene was not in the script but rather presented to her on-set by Brando and Bertolucci without any warning and that it was tantamount to an actual assault. Bertolucci confirmed Schneider's accusation in a 2013 interview, saying that he and Brando purposely kept her in the dark in order to provoke a more "authentic" reaction, but denied that his choice could, or should, be considered an act of sexual violence in itself. Schneider was only 19 at the time of filming.

If you or anyone you know has been a victim of sexual assault, help is available. Visit the Rape, Abuse & Incest National Network website or contact RAINN's National Helpline at 1-800-656-HOPE (4673).

Child actor Brooke Shields' breakthrough starring role came in Louis Malle's 1978 drama "Pretty Baby," an elegiac look back at World War I-era New Orleans told from the perspective of a 12-year-old sex worker named Violet. Raised in a brothel by her mother (Susan Sarandon), Violet eventually enters the family business. Her virginity is auctioned off to the highest bidder, and after her mother abandons her for a wealthy john, she falls into a marriage of sorts with an obsessed photographer (Keith Carradine). The plot may sound salacious, but the film itself is anything but. Though Malle and co-writer Polly Platt may have some affection for the music and styles of the era, they also understand that sex work is often boring and often dangerous but rarely sexy.

Still, this is a film in which a preteen actor appears in several nude scenes, and for many people, that was a bridge too far. Shields' mother and manager, Teri, had to defend her daughter and herself against accusations that the film was nothing more than child pornography. Shields went on to make many other films, but "Pretty Baby" still holds a significant place in not just her filmography but the public's perception of her. When "Pretty Baby" turned 40 back in 2018, Shields told Vanity Fair that she still considers it the "best creative project [she's] ever been involved with," though she conceded that if she were in her mother's place, she might not have been so quick to sign off on the project for her own daughter.

Before "The Blair Witch Project," there was "Cannibal Holocaust." The 1980 horror flick presents itself as a documentary within a documentary, in which an anthropologist (Robert Kerman) travels to the Amazon in search of a missing film crew but finds nothing but bones and the grisly footage that serves as their last will and testament. Even four decades later, the film's makeup effects are gruesomely convincing, as the documentary crew gets maimed, flayed, and beheaded by the indigenous tribe they came to document. There is a fair amount of "National Geographic"-style nudity, and two actresses appear nude in more graphic scenes.

To maintain the illusion that what audiences saw was real, director Ruggero Deodato hired unknown actors and had them keep a low public profile. His plan, however, worked a little too well. After the film's premiere, Italian authorities seized the prints and arrested Deodato on obscenity charges. When the media couldn't immediately prove that "Cannibal Holocaust" wasn't a snuff film, the Italian government added a murder charge, too. The actors had to prove to the court that they were still alive before the charges were dropped. Deodato may have beaten a murder rap, but he was fined for the very real animal cruelty depicted on screen, and the film was banned for three years.

In 1988, Martin Scorsese finally realized a long-awaited dream project: bringing Nikos Kazantzakis' novel "The Last Temptation of Christ" to the screen. Starring Willem Dafoe as Jesus, the film eschews the pomp of Bible epics past in favor of something more intimate, contemporary, and, at times, surreal. Harvey Keitel's Judas sounds like a New York tough guy, while Harry Dean Stanton's Paul is a Southern evangelist. The approach would have likely been controversial even if Scorsese hadn't adapted the novel's main conceit — the titular "last temptation," when Jesus, dying on the cross, receives a vision of his life as a mere mortal, wedding Mary Magdalene (Barbara Hershey), raising a family, and growing old in a doomed world that never heard his message.

Marriages are consummated, of course, which the film depicts in a nude scene with Dafoe and Hershey. The very idea of Jesus having sex — even within the confines of marriage and even within a fantasy that he and the film ultimately reject — infuriated religious groups around the world. The film was derided as evil and anti-Christian, protested by religious groups of all stripes, and even banned in some countries and by some domestic exhibitors (including Blockbuster Video). "I expected some controversy with 'Temptation,'" Hershey — who actually gave Scorsese Kazantzakis' novel during the filming of "Boxcar Bertha" years earlier — told the Chicago Tribune in 1989. "But nothing like what happened."

While nude scenes in films became largely accepted after the fall of the Hays Code, television took things a little slower. Brief, nonsexual nudity was allowed on the small screen in a few of the prestige miniseries of the 1970s and '80s — "Roots," "Holocaust," and "Lonesome Dove" — but the series that truly paved new roads for what was acceptable on network television was 1993's "NYPD Blue." 

Created by superproducer Steven Bochco and future "Deadwood" creator David Milch, the show spent 12 seasons pushing the envelope and fighting censors, advertisers, and the network. The very first episode features a nude love scene — tastefully obscured by shadows — between David Caruso's veteran detective, John Kelly, and Amy Brenneman's beat cop, Janice Licalsi. Dennis Franz, as scumbag detective Andy Sipowicz, dropped trou for a shower scene in Season 2, and before long, appearing nude on screen became something of a rite of passage for the actors on "NYPD Blue."

Ultimately, the threats of affiliate boycotts and protests only helped to bolster the show, which was a critical and commercial smash right out of the gate. Every so often, though, "NYPD Blue" ran into some actual trouble, as in 2003 when the FCC issued a $1.2 million fine for a nude scene involving actress Charlotte Ross and her "nude buttocks," which were visible for seven seconds, according to the complaint. The legal battle over the fine stretched out for nearly a decade before an appeals court finally struck it down in 2011.

The success of films like "Fatal Attraction" and "Basic Instinct" resulted in a brief vogue for erotic thrillers in the early 1990s. One of the most notorious was Richard Rush's "Color of Night" from 1994. Bruce Willis, then one of the biggest stars in the world, stars as Bill, a traumatized psychiatrist who takes on his murdered colleague's group therapy sessions at the same time as he begins an intense sexual affair with a mysterious beauty named Rose (Jane March). Could there be a connection between Rose, the therapy group, and a killer on the loose? Has Bill's erotic fixation on Rose put his life in danger?

Even before the film was released, it was raising eyebrows over its sexual content. Rumor had it that both March and Willis showed full frontal nudity in their frenzied sex scenes. But as passionate as things got on screen, the real heat of the production was happening behind the scenes as Rush and producer Andrew Vajna fought over the film's final cut. Reportedly, Rush's vision was of a darker, more explicit film, while Vajna's priority was one that could earn an R rating and possibly make some money. The ugly industry fight turned even uglier when Rush suffered a severe heart attack in the course of negotiations. Vajna ultimately brought in director George P. Cosmatos ("Tombstone") for reshoots, and the film was released with an R rating and middling reviews.

If you or someone you know needs help with mental health, please contact the Crisis Text Line by texting HOME to 741741, call the National Alliance on Mental Illness helpline at 1-800-950-NAMI (6264), or visit the National Institute of Mental Health website.

On a 1996 episode of the sitcom "NewsRadio," eccentric billionaire Jimmy James (Stephen Root) makes a joke about "that sweet girl from 'Saved By the Bell'" doing a "dirty movie." That "sweet girl" was actress Elizabeth Berkley, and the "dirty movie" in question was Paul Verhoeven's "Showgirls," the immediately notorious 1995 satire set in the garish world of Las Vegas nude dancers. As we've seen elsewhere on this list, it's pretty rare for an actor to take the fall for an entire film; blame usually falls on the director more than anyone else. But unfortunately, Berkeley became inextricably linked to "Showgirls," its infamy, and its box office failure. That "NewsRadio" joke was an accurate summary of public opinion at the time.

The film is a riff on "All About Eve," with teenage runaway Nomi (Berkley) setting her sights on the reigning queen of the Vegas scene (Gina Gershon). The NC-17 rating had been introduced just a few years earlier as a replacement for the stigmatized X, and "Showgirls" was the first studio film to attempt a wide release under that banner. But audiences and exhibitors turned out to be just as gun-shy about NC-17 as they were about X, and the dream of a non-controversial adults-only rating vanished into dust. Berkley's career was adrift for a few years after "Showgirls," but in the 21st century, she has built up a respectable resume on stage and screen. The film, meanwhile, has rightly been recognized as a cult classic.

On-set romances are as old as Hollywood itself. When two extremely attractive people are up on screen sharing a heavy love scene, or even just a kiss, it's natural to wonder if their relationship was more than strictly professional. In 2001, there were perhaps no hotter stars in Hollywood than Angelina Jolie and Antonio Banderas, who starred together that year in Michael Cristofer's steamy noir "Original Sin." Banderas plays a turn-of-the-century Cuban plantation owner whose beautiful new mail-order bride (Jolie) turns out to be more than she appears. Both stars were married at the time, Jolie to her "Pushing Tin" co-star Billy Bob Thornton and Banderas to his "Two Much" co-star Melanie Griffith, but rumors arose that the two were carrying on behind the scenes.

Jolie laughed off the rumors at the time, pointing out that because the twists and turns of the plot were kept under wraps, people latched onto the one thing they could see. Banderas also denied the rumors, and in a 2007 Daily Mail interview, he disabused anyone of the notion that filming love scenes with Jolie was as pleasurable as it looked on screen. "I couldn't touch her, because she had tattoos everywhere and they had to be covered with makeup, so I had to try not to dislodge it," Banderas said.