A new study shows children are just as upset by depictions of violence, animal cruelty, and parental snarking online as they are by sexual imagery and bullying.

This research, conducted by the UK Council for Child Internet Safety (UKCCIS) and slated to be revealed on Tuesday, Feb. 5, shows that Internet filters and parental controls for sexual content are only a half measure when it comes to protecting children who use the Internet.

For the study, UKCCIS asked 24,000 school-aged children as old as 16 about their online habits, including the question, “Have you ever seen anything online that upset you?”

According to the to-be-released report, entitled “Have Your Say,” the children’s answers ranged broadly from YouTube videos depicting animal deaths to Facebook reminders of broken homes.

However, the kids said they mostly used the web for playing games, doing homework, and social networking — all in all, mostly positive or at least harmless activities.

And while parents have recently voiced concerns to government officials about kids being able to access pornography while online, children seemed more likely to be disturbed by mean comments from friends or even family and images of violence on the web.

As researcher and academic Andy Phippen told The Guardian, “There is no silver bullet to crack child safety online. Government’s obsession with filtering is okay, but too narrow.”

The UK government’s most recent set of proposals focused on parental controls provided by ISPs, telecoms, OEMs, web services, and even retailers “to develop universally available, family-friendly Internet access which is easy to use” and to “improve online protections for the more vulnerable children.”

The proposal also seeks to better define what content is inappropriate — including upsetting, mean, and violent content — and develop better ways to identify and eliminate it before children are exposed to it.

Greg Perreault, a doctoral student in the university’s School of Journalism, recently examined five titles that incorporate spiritual themes in their storylines — Mass Effect 2, Final Fantasy XIII, Assassin’s Creed, Castlevania: Lords of Shadow, and The Elder Scrolls IV: Oblivion. He found that each game “problematized religion” by closely tying it to violence.

“In most of these games there was a heavy emphasis on a ‘Knights Templar’ and crusader motifs,” he said. “Not only was the violent side of religion emphasized, but in each of these games religion created a problem that the main character must overcome, whether it is a direct confrontation with religious zealots or being haunted by religious guilt.”

Perreault (pictured) tells VentureBeat his study did not originally focus on violence. “In general, I tend to think that studies of violence in video games are passe. I set out interested in the depictions of organized religions versus spiritual religions, expecting to find organized religions depicted far more poorly than spiritual [ones].”

However, he says a game that connects religion with violence isn’t necessarily portraying it negatively. He uses the character Thane in Mass Effect 2 as an example, a deeply spiritual assassin who joins in the player’s quest to save the galaxy from the Reapers. “This is an interesting case because his religion doesn’t ‘inform’ the violence, although it allows for it,” he said. ”His religion basically says that the body and soul are separate. So the body can be used as a tool by someone else, and thus his assassinations aren’t anything he bears guilt for — the person who hired him bears the guilt. But Thane still feels guilty. He thinks about his victims, he prays for his victims. So is the religion violent here? Not necessarily, although it allows for the violence he commits — and must commit – in order to save the galaxy.”

While he cites Mass Effect 2 as an example of a game that portrays its spiritual themes in a positive light, Perrault says Assassin’s Creed is the most critical title he researched. “The game revolves around the search for something called the Piece of Eden. It allows you to control people’s minds. The argument is that the parting of the Red Sea, the turning of water into wine, the Resurrection — all of it was courtesy of church leaders who used the Piece of Eden to convince people a miracle occurred. The Templars, who appear to be exactly what they’re called, want it so they can use it to control the people. The Assassins, who are depicted as Enlightenment era secularists, want to keep it from them. As it turns out in the end, the Assassins don’t have good intentions with this thing either.”

Aware of the problems it could cause, Ubisoft puts a disclaimer on each Assassin’s Creed title saying that the game was designed by a “multicultural team.”

While the study observed a relationship between violence and video games, Perreault says he does not believe developers are creating an intentional commentary on religion.

“It doesn’t appear that game developers are trying to purposefully bash organized religion in these games. I believe they are only using religion to create stimulating plot points in their storylines. If you look at video games across the board, most of them involve violence in some fashion because violence is conflict and conflict is exciting. Religion appears to get tied in with violence because that makes for a compelling narrative.”

“I hope [the developers] take away that the thoughtful writing and imagery of their games doesn’t go unnoticed,” he added. ”I hope this propels great writing into all the great conversations of our society in video games, which I think ultimately will lead to better and better games.”

Perreault presented his findings at the Center for Media Religion and Culture Conference on Digital Religion.

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The state law restricted the sale or rental of violent video games to minors, but the court upheld a Ninth Circuit court of appeals ruling that said the act violated the First Amendment. For the first time, the highest court in the country will give games the same legal protection that books, plays, and movies enjoy, because games “communicate ideas through familiar literary devices and features distinctive to the medium.” The court cited a previous case that held, “the basic principles of freedom of speech do not vary with a new and different communication medium.” With that, a long chapter of legal warfare will end and the video game industry can enjoy its own measure of creative freedom.

The Justices voted 7-2 to strike down the California law. Justice Antonin Scalia wrote the majority opinion, while Justices Stephen Breyer and Clarence Thomas offered dissenting opinions. Justices Samuel Alito and John Roberts also concurred with the majority and wrote a separate concurring opinion.

The decision lifts a cloud that has for years hung over the video game industry, which is becoming one of the biggest forms of entertainment. Faced with regulatory restrictions in the 1980s, the game industry introduced a voluntary ratings system for games to help parents shelter their children. But opponents ratcheted up their efforts to ban violent games state by state, and the industry responded with its own legal efforts that have now succeeded. Game designers can now create games without worry that they will fail to get mainstream distribution based on the content in the games.

“We are thrilled by today’s news,” said Jennifer Mercurio, vice president and general counsel of the Entertainment Consumers Association, a game industry consumer group. “We had hoped that we would see this decision, and it’s been a long time coming. That being said, there will probably be one or two legislators who attempt to test these new parameters, and the ECA will continue to fight for the rights of entertainment consumers.”

See more reactions here.

One of the big problems with the law was its attempt to define what kinds of violence were considered inappropriate for children. Not only is it hard to create such definitions, it’s also hard to justify them with scientific research.

Scalia noted that Dante’s Inferno and the Grimm’s Fairy Tales depict violent scenes but have never been restricted. “Reading Dante is unquestionably more cultured and intellectually edifying than playing Mortal Kombat. But these cultural and intellectual differences are not constitutional ones. Crudely violent video games, tawdry TV shows, and cheap novels and magazines are no less forms of speech than The Divine Comedy.”

“California’s act does not adjust the boundaries of an existing category of unprotected speech to ensure that a definition designed for adults is not uncritically applied to children,” Scalia wrote. “The state wishes to create a wholly new category of content-based regulation that is permissible only for speech directed at children. That is unprecedented and mistaken.”

He went on to say that the court found unpersuasive the state’s claim that video games are special because players participate in the interactive act of violence. The state failed to justify singling out video games in arguing for a “compelling government interest” in the restrictions. Scalia said that psychological studies purporting to show a connection between “exposure to violent video games and harmful effects on children do not prove that such exposure causes minors to act aggressively,” as the effects are small and indistinguishable from the effects produced by other media.

Scalia said the game industry’s existing voluntary rating system accomplishes the goal of giving parents a choice about whether to restrict their children’s access to violent games.

“We have long recognized that it is difficult to distinguish politics from entertainment, and dangerous to try,” Scalia said.

In the concurring opinion, Justice Alito argued that it was important that the state only restricted the sale or rental of games, rather than the “creation or possession” of violent games. But Scalia and others in the majority opinion found that to make no difference.

Justice Alito’s opinion opened with a comment on how the effects of new technology are unpredictable. He noted that spending hours controlling the actions of a character who guns down innocent victims might actually be different in kind from reading a description of violence in a work of literature. He found the increasing realism of violent games to be disturbing. Motion-sensing systems (such as Microsoft’s Kinect) can now enable players to mimic violent actions to produce a violent effect on the screen, like swinging a baseball bat to “smash a skull.”

“These present-day and emerging characteristics of video games must be considered together with characteristics of the violent video games that have already been marketed,” Alito said. “In some of these games, the violence is astounding.”

Those in favor of the law curbing the sale of violent video games argued that the case was similar to obscenity laws, but Alito and Scalia pointed out that there is a long history of agreement about what constitutes obscenity in the country, while there isn’t a similar tradition about violence.

Justice Breyer, in his dissenting opinion, said parents are simply unable to keep track of all of the content their children consume. He noted that 5.3 million grade-school age children are routinely home alone. He also noted that Federal Trade Commission tests show that kids are able to buy mature-rated video games in stores without parental approval as many as 50 percent of the times they try. Applying a “modest” restriction on speech to help parents in the compelling need to protect children is a small price, Breyer said.

He said that it is possible to define violent games that are the most realistic and potentially damaging. He found California’s description of violence with words such as “kill,” “maim” or “dismemeber” to be precise enough to be enforced, much like the term “nudity” in anti-obscenity laws. Breyer said that evidence submitted by California about the effects of violent video games on children was more extensive than that submitted for obscenity laws.

“The statute prevents no one from playing a video game, it prevents no adult from buying a video game, and it prevents no child or adolescent from obtaining a game provided a parent is willing to help,” Breyer wrote. “All it prevents is a child from buying, without a parent’s assistance, a gruesomely violent video game of a kind that the industry itself tells us it wants to keep out of the hands of those under the age of 17.”

Justice Thomas, in his dissenting opinion, argued that parents have authority over children and can thus control what speech their children hear or see. He says there is a long tradition behind that belief and that video game publishers do not have the unfettered right to speak to children without restraints. He noted that the law does not ban the sale of violent games to minors; rather, the law allows parents to buy violent games for minors if they so choose.

The high court’s members had signaled that they didn’t favor restrictions on video game sales back in November, during oral arguments.

The case is the culmination of a six-year legal battle in California. The state’s Attorney General Zackery Morazzimi, on behalf of new Gov. Jerry Brown, argued that the “deviant level of violence that is presented in a certain category of video games” requires legal restrictions to protect children.

But during the oral hearings, Justice Scalia almost immediately interrupted, pointing to Grimm’s fairy tales and saying, “So are you going to ban them too?”

Scalia added, “You are asking us to create a whole new prohibition … what’s next after violence? Drinking? Movies that show drinking? Smoking?”

Justice Ruth Bader Ginsburg said, “What about films? What about comic books? Why are video games special?”

Morazzimi also came under fire about the vagueness of California’s law, which seeks to define video game violence but does not spell out exactly what is allowed or not. Justice Elena Kagan asked Morazzimi if Mortal Kombat should be banned from sale to kids, and he said he didn’t know. Scalia joked that he played the game.

Back in 2005, then-Gov. Arnold Schwarzenegger signed a law authored by state senator Leland Yee of San Francisco that made it a crime to sell games to kids under 18 where the game depicts acts such as “the needless mutilation of the victim’s body.” U.S. District Court judge Ronald Whyte blocked it on First Amendment grounds, as had other courts around the country with similar laws.