We may differ in our interpretations but it does not mean my interpretation is a "dumb take" nor does it make my understanding "shallow". Name calling and insults are not constructive to any discussion.

Campbell concerned parody, not direct background image use. Indeed, it has been recently narrowed in at least 4 subsequent SCOTUS cases, notably in Eldred v Ashcroft, which stated "[t]he fair use defense affords considerable "latitude for scholarship and comment"". Logically that means that different people will have different comments. In my opinion and based on my readings of the case law, filming another work where it only appears in the background is unlikely to be considered fair use.

If you had wanted to really tear my response and knowledge of copyright law down, you may have wanted to cite the recent Gayle v HBO from the SDNY, while telling me that fair use is not the defense in primary question because a plaintiff must first overcome the hurdles associated with the second prong of infringement, substantial similarity. Substantial similarity requires protected expression plus more than de minimus use, and the court held in Gayle that 2-3 seconds of potential visibility was insufficient to sustain an infringement claim. That could be the case based on this hypothetical.

Conversely, it may also not be, and fair use could have a stronger position. Ringgold v. Black found that 4-5 seconds was not de minimus, and, in analyzing fair use, found that use as background decor was not transformative--while citing to the law review article you cited--because visual works are most often created for their decorative value, and using it in the background is also decorative. This is where I land, and I take a conservative view of not fair use without more.

We can disagree, but that does not make me ignorant.