Some realists only sought to demonstrate that law is neither autonomous, apolitical, nor determinate. For example, jerome frank , who coined the term legal realism and later became a judge on the . Court of Appeals for the Second Circuit, emphasized the psychological foundation of judicial decision making, arguing that a judge's decision may be influenced by mundane things like what he or she ate for breakfast. Frank believed that it is deceptive for the legal profession to perpetuate the myth that the law is clearly knowable or precisely predictable, when it is so plastic and mutable. karl llewellyn , another founder of the . Legal Realism movement, similarly believed that the law is little more than putty in the hands of a judge who is able to shape the outcome of a case based on personal biases.
Kino-eye, composed of various newsreel correspondents, editors, and directors, also took indirect aim at montage as the overarching principle of cinema. Kino-eye was interested in capturing life of the proletariat and actualizing revolution, and was accused by Eisenstein of being devoid of ideological method. Films like Dziga Vertov’s The Man with a Movie Camera utilized montage (almost all films did at the time), but packaged images without discernible political connection between shots. Vertov, on the other hand, saw the fictional revolutions represented in Eisenstein's films as lacking the visceral weight of unscripted action.