As a backlash to Bette Davis being overlooked for a nomination for her heavily favored performance in Of Human Bondage, the Academy allowed write-in votes in 1934 and 1935, meaning you didn't have to be nominated to win. The only person who ever won this way was cinematographer Hal Mohr, for his work on A Midsummer Night's Dream.

Mohr had a distinguished 50-year career as a cinematographer and would go on to win a second Oscar for Phantom of the Opera (1943) and a nomination for The Fourposter (1953). He is also one of only six cinematographers to have a star on the Hollywood Walk of Fame in Los Angeles.