"smokes in many scenes to cement the image that she is 'bad'"
Other references to this movie:
Loretta Young - Info - "The 'bad' in [Born to Be Bad (1934)] is Loretta Young, and one of the chief pleasures to be derived from this melodramatic hour-long chestnut is watching America's sweetheart play completely against her screen-image by chain-smoking cigarettes, talking in her best 'Noo Yawk' accent, and giving up lots of hateful little glances.", website, when?
, Allposters.com