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From Wikipedia:
In Batman (1989), Billy Dee Williams appears as a Harvey Dent before his disfigurement, vowing to reduce crime by locking up mob boss Carl Grissom. Williams was set to reprise the character as Two-Face in the sequels, but the Harvey Dent character was deleted from the script for the sequel Batman Returns (1992), and Batman Forever (1995) ...
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Artistic freedom allows him to do this. Besides, those early superhero worlds were 100% white. It may have been considered tasteless to have a black character play a villain, which could have been construed as racist by all those happy race-baiters.
If you're saying Dent appeared in an earlier Batman movie (I don't really recall those Burton ones too well....
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