Judas Priest Ruling Still Leaves Other Issues in the Air : Trial: Implications are uncertain regarding the creative freedom of artists in movies and television.

For television producers and feature filmmakers, implications of the Judas Priest decision are uncertain.

On the one hand, it’s easier to prove whether a subliminal message has been inserted into a movie or television program than a record, because the film or tape can be run at a slow speed to see if the message appears. Typically, the messages are inserted by placing a small number of frames bearing the message--just enough to show the image for a fraction of a second--between the frames of the feature.

Executives at many of the major Hollywood movie studios declined to comment on the impact of the case, but subliminal messages have shown up occasionally in films. Warner Bros., for example, has acknowledged inserting an image of a “death mask” in “The Exorcist.”

In the Judas Priest decision, Washoe, Nev., District Judge Jerry Whitehead said that subliminal images and messages have been used in films to promote products. However, while mentioning these uses, Whitehead did not offer specific recommendations.

The use of subliminal messages in television has been prohibited by FCC policy since the 1970s. No such government agency oversees the film industry.

For television, the case still brings up other issues.

In a number of cases people have claimed that crimes were committed in imitation of television depictions. Shortly after the NBC movie “Born Innocent” depicted a scene in which an adolescent, played by Linda Blair, was raped with the handle of a toilet plunger, a group of youths raped a girl with a beer bottle. The victim’s parents claimed the crime was inspired by the TV program and sued NBC.

Similarly, after the NBC television movie “The Burning Bed” depicted actress Farrah Fawcett setting her abusive husband on fire, victims and perpetrators in a number of subsequent burning cases tried to blame the network. In one case, a man pleaded guilty to setting his wife on fire after seeing the movie.

“The legal standard says that there is a difference between inciting people to take certain actions and merely dramatizing stories,” said Joe Rutledge, vice president of corporate communications of NBC.

“I can’t imagine that we would be even remotely culpable for ever inciting individuals to take actions,” Rutledge said. “We merely present dramatizations and report news and sports.”

Incidents such as those involving “The Burning Bed” and “Born Innocent” are isolated, Rutledge said, and network officials are not concerned that the Judas Priest decision will open the way for future suits.

But Barbara Goen, spokeswoman for KCET-TV Channel 28, Los Angeles’ public television station, said she thinks the suit and ruling are part of a dangerous pattern.

“It seems to be part of an uncomfortable trend to limit the creative freedoms guaranteed in the Constitution,” Goen said.

Courts have been reluctant to accept defense arguments that claim perpetrators of crimes should be absolved because they were “brainwashed” or unduly influenced by television. Similarly, suits against networks and television producers by people who claim they were injured as a result of a program have not tended to be successful.

Times staff writer David J. Fox contributed to this article.