First: the use of the word "hell".

While usage of the word "hell" wasn't exactly common in films of the 1930s, it wasn't unheard of, either. The word appeared in the names of several major films produced or distributed by the major studios in the Pre-Code era. Among them are Hell's Angels (United Artists, 1930), Doorway to Hell (Warner Brothers, 1930), Safe in Hell (Warner Brothers, 1931), Merrily We Go to Hell (Paramount, 1932), Hell's Highway (RKO, 1932), Laughter in Hell (Universal, 1933), and The Mayor of Hell (Warner Brothers, 1933).

The word also popped up occasionally in spoken dialogue. One of the earliest examples is in the film Paradise Island (Tiffany Pictures, 1930), where the leading man asks the leading lady if she'll marry him. "Hell, yes!" she replies.

In the cartoon "The Milkman" (Ub Iwerks Studio, 1932), starring Flip the Frog, Flip and his friend sing a line from the song "The Gang's All Here", and the horse they are riding responds with, "What the hell do we care?". Flip admonishes the horse, to indicate it wasn't entirely acceptable, but the fact that the word was said in a cartoon for laughs shows that the word could get passed the censors in the Pre-Code era in some rather unexpected places.

However, both of these examples come from minor studios, not from any of the eight major studios, although in the case of Flip the Frog, that comes with a caveat. The production company was independent, but they had a contract with MGM to distribute their cartoons in MGM theaters (the Loew's theater chain). Had MGM produced it themselves, it's probably less likely it would have been accepted. The majors seemed to be a little more reserved in the use of such language, but there are several examples of "hell" being used in major motion pictures of the era as well—but usually as a physical place rather than an adjective. For example, in MGM's The Big House (1930), there is a scene where some prisoners attempt to escape, only to end up in a gunfight with the prison guards. When the prison warden is informed that the prisoners are willing to negotiate, he responds, "I'd see them in hell first," and the gunfight resumes.

That said, the use of profanity wasn't limited to the word "hell". There are other examples of Pre-Code films that use the words "damn", "damned", "ass", and "jackass" in spoken dialogue, in the way that you'd expect a profanity to be used. More commonly, though, the profanity was implied. Characters would say things like, "Son of a --" and not finish the line.

So, is the use of "hell" in Angels with Filthy Souls consistent with what can be found in Pre-Code films? Yes, although it would have still stuck out in the era as one of the more extreme examples of casual swearing in a major motion picture (assuming it was one of the major studios who produced it).

Second: the use of violence.

There are actually three important aspects to the brief scene in Angels with Filthy Souls. First, Johnny shoots Snakes. Second, we see Snakes get shot and die. And third, Johnny laughs about it. Any two of these aspects probably would have passed the censors in the Pre-Code era. Seeing Johnny shooting and laughing while Snakes gets away? Sure, possibly. Seeing Snakes get shot and die, but without the laughter? Sure, several gangster films of the Pre-Code era featured on-screen deaths. Hearing the laugh and then a cut to Snakes' dead body, but no actual gunfire? Maybe that, too. But all three? While not impossible, it surely would have been about the most extreme Pre-Code scene of the era, and probably would have ushered in the Hays Code enforcement much sooner, if the studio had been brave enough to release it.

Another important aspect would have been: what happens to Johnny by the end of the film? If he were to eventually meet his own demise, and regret all his previous bad behavior, then there would have been a much better chance for this scene to get past the censors in the Pre-Code era. The Pre-Code era did have gangsters who would get away with murder sometimes, and never show remorse, but this scene in Angels with Filthy Souls is kind of pressing all the buttons at once. We hear profanity, we see the use of violence and firearms, we see an onscreen death, and we see a "bad guy" enjoying his bad behavior and never expressing remorse. Had it made its way to the public, it would have been Exhibit A of what the Hays Office and the public advocacy groups of the era were complaining about.

In the book Pre-Code Hollywood Sex, Immorality, and Insurrection in American Cinema 1930-1934 by Thomas Doherty (Columbia University Press), the author cites the three films Little Caesar (1930), Public Enemy (1931), and Scarface (1932) as having "cast the mold for the gangster genre" during the Pre-Code era. In all three, we see explicit violence, and some onscreen death, but we don't see the main character get away with it. Eventually, they meet their comeuppance. Doherty singles out Scarface as causing particular uproar, due to its graphic depictions:

"Of all the gangster films, Scarface was the most controversial and violent...Unprecedented in the context of the times, the violence in Scarface shocked and outraged editorialists, politicians, and, it seemed, anyone within reach of a pen or typewriter. A vitriolic front-page commentary by Jack Alicoate in the Film Daily, a trade paper that was more often an industry shill than critic, said Scarface generated a 'distinct feeling of nausea,' the action was 'so compellingly forceful as to leave one limp,' the only suspense lying in 'the additional brutal methods employed in each new massacre.' 'There are certain things that simply do not belong on the screen,' declared Alicoate. 'The subject matter of Scarface is one of them. To show it indiscriminately on the screens of America will do more harm to the motion picture industry and every one connected with it than any picture ever shown.' He added firmly: 'It should never have been made.'...The tonal shifts in Scarface, the carefree blend of brutal violence and light comedy, particularly disturbed critics."

Now, consider that the scene in Angels with Filthy Souls ends with a joke ("Keep the change, you filthy animal"). If Scarface upset critics, then Angels with Filthy Souls would probably have ended careers for some film executives, and maybe some actors, too.

On the other hand, part of the criticism of Scarface is that there's also quite a lot of violence. It isn't just confined to a single scene, but there are at least a half-dozen scenes and sequences throughout the film that critics found problematic. So, with Angels, it would depend on the content of the rest of the film. Is this by far the worst offender in the film, and the rest is relatively trouble-free, while Johnny eventually shows remorse as he takes his dying breath? Then maybe it would have made it through. But is this just one of many such scenes in the film? Then definitely not. But maybe we should give the benefit of the doubt here -- this is clearly Kevin MacAllister's favorite scene in the film, so maybe nothing else in the movie comes close.

To conclude, I'd defend the scene in Angels with Filthy Souls as a good caricature of what you're likely to encounter in the more notorious Pre-Code films. Certainly, nothing that hit all the hot-button criticisms of the era ever appeared in such quick succession in a single scene. But had all the elements appeared in a single film, with the more controversial aspects happening a bit more separately, spread throughout several scenes in the film, then this wouldn't have been too over the top. It still would have been at the more notorious end of the spectrum, but still, the elements are all believable, and are all found in Pre-Code films.

With the full enforcement of the Hays Code in 1934, though, nothing like this would have ever got its MPAA "Pass" rating to be shown publicly. It would never have been greenlit by the studio in the first place. While scaled-back aspects of each of these were still possible (there's an occasional "damn" or "hell" in otherwise unobjectionable movies; there's still gangster violence but mostly off-screen and always in a way that you never root for the bad guy), nothing like this would have been seen again until the 1960s. The appendices in Doherty's book reproduces some of the guidelines in the Hays Code. Some of the pertinent guidelines include:

"Brutal killings should not be presented in detail."

And:

"Criminals should not be made heroes, even if they are historical criminals."

And:

"Pointed profanity (this includes the words, God, Lord, Jesus, Christ—unless used reverently—Hell, S.O.B., damn, Gawd), or every other profane or vulgar expression however used is forbidden."

Oh, and one more. The scene starts with Snakes saying something about having "got the stuff". Presumably, the rest of the film would explain what this "stuff" is, but if it's drugs, it just piles onto why the Hays Code would never have allowed this:

"Illegal drug traffic must never be presented. Because of its evil consequences, the drug traffic should never be presented in any form. The existence of the trade should not be brought to the attention of audiences."

So, again, it's actually a pretty accurate, albeit over-the-top caricature of most of the complaints against gangster films in the Pre-Code era, all concisely fit into an 83-second scene, but no single scene like this ever existed. And then in the Hays Code era, nothing remotely like this was ever produced, let alone allowed.