Unmanned_Aerial_Vehicles_and_Photography_Final

This report will give a brief review on
historically important court cases and
legislation involving photography. The
report will then cover current uses of
photography, specifically to unmanned
aerial systems, and then give
recommendations for good business and
government practice.
Unmanned Aerial
Systems,
Photography, and
Information
A concise review of law, types of
photography, and issues that arise.
Brian Kronenberger

Unmanned Aerial Systems, Photography, and Information April 8, 2015
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Table of Contents
Overview ...........................................................................................................................................2
Introduction.......................................................................................................................................3
Understandings..................................................................................................................................3
Civilian Unmanned Aerial Vehicles...................................................................................................3
Infrared and Sensor Technology.......................................................................................................4
Expectation of Privacy.....................................................................................................................4
Airspace, What You Own.................................................................................................................4
Governments View of Expectations of Privacy ..................................................................................5
Government’s Right to See Pictures obtained by others....................................................................5
Legislation..........................................................................................................................................6
First Amendment............................................................................................................................6
Fourth Amendment ........................................................................................................................6
USA PatriotAct,..............................................................................................................................6
Federal Aviation Administration.......................................................................................................7
Historical Court Rulings.......................................................................................................................7
Nussenzweigv. diCorcia 2007..........................................................................................................7
Kyllo v. United States 2001 ..............................................................................................................8
Smith V. Maryland..........................................................................................................................8
Challenges and Recommendations ......................................................................................................9
Issues Involving UnmannedAerial Systems.......................................................................................9
Recommendations andAnswersfor Flight....................................................................................9
Issues Involving Cameras on Unmanned Aerial Systems?.................................................................10
Recommendations for Camera Use While in Flight ......................................................................10
The Rights of a Photographers after the Picture is Taken.................................................................11
Conclusion .......................................................................................................................................12
Websites..........................................................................................................................................12
References.......................................................................................................................................13

2
Overview
Over the past decade, unmanned aerial systems (UAS, UAV, Drones) have turned from a
futuristic notion heard on television to now an everyday term used within common place
society. As the skyways become a crowded area of watchful eyes and wall piercing sensors, it
may give a feeling of a metaphorical panopticon, big brother feel. This document will provide
the concepts that the government has instituted to give photography users the fair guidelines
for what is legal and what isn’t. The document also provides the difference between what is
legal for the government and what is legal for the citizen. In the end, it will provide
recommendations for citizens, businesses, and governments entities to protect against legal
recourse for privacy infringements.

3
Introduction
The closer that society throughout the world gets closer to achieving open airways for
unmanned aerial systems the closer society is going to have to look at privacy and photography
laws. Technology is far surpassing what our laws dictate what a person or government can do
with given sensor technology. There are already cameras that can look into a house using
different forms of technology, unmanned aerial vehicles that reach heights most conventional
planes cannot, and global monitoring satellites that can take pictures with incredible detail.
As far as this document is concerned case law and legislation are the same but explained in two
different sections. Case law and legislation are noted as being the same because they both give
court proceedings prior rulings and legal documents so that the court can give a ruling that
wouldn’t contradict a prior ruling. However, both case law and legislation are privy to the
Supreme Court and can be amended by the Supreme Court. There are many issues that are
brought up that involve privacy and photography laws. Privacy laws are brought into this
document to give a full scope of what is to be expected by persons taking the pictures and the
objects/people having their pictures taken. Photographic laws are brought up because this
document needs to address what is legal for photographers, using both aerial and ground
capabilities.
Challenges brought up in this document will address what governmental bodies, individuals,
and corporations will have to address when using photography, especially when flying
unmanned aerial vehicles.
This paper seeks to provide direction and recommendations, concerning guidelines and best
practices when using unmanned aerial vehicles for photography.
Understandings
Some of the terms used in this paper will need a certain level of explanation. The section below
is meant to inform the reader of these terms so that this document will be easily read by
individuals who are planning to use unmanned aerial vehicles with photographic capabilities. It
will also cover different ideas of privacy so that the reader can ascertain the different levels
privacy and what is monitored.
CivilianUnmanned Aerial Vehicles
Most unmanned aerial systems that civilians can buy range from a weight capacity of up to
1300 grams. (Phantom 2 Spec Sheet) The Phantom 2 is a widely sold and used UAS across the
whole world. It is one of the first mass marketed unmanned aerial systems to take hold to the

4
general public. The sensor on the Phantom weighs approximately 300 grams. A Phantom 2 can
easily hold a Go-Pro or even an infrared sensor with ease. (DJI, 2015)
Infrared and Sensor Technology
An infrared camera has the ability to detect the variations of heat signatures. With infrared, a
sensor will be able to see in perfect darkness as long as what it is looking at emits heat. An
infrared camera can be used at any time during the day or night, but has better at effect at
night because the sun will heat up surrounding objects, overexposing the effect. Other sensors
are able to detect variations in other electromagnetic spectrums that the naked cannot see,
such as ultraviolet. This technology is used in many applications, crop monitoring, law
enforcement, military, and others. When pictures or videos are taken using these sensors, it
gives the data gathered different colors to show variations that a human see. Such as taking a
picture with an infrared camera of a human in darkness, the picture can show heat signatures in
variations of the color spectrum. A human would look brightest in the center while slowly
changing colors out to the extremities. This type of view is what is called a passive view,
meaning it is detecting the radiation. Opposite to that is an active view. Active viewing sends
out waves or particles that will bounce off the objects, reflecting back to the sensor. An
example of active sensing is X-ray technology which will send X-rays through objects, bouncing
off of denser objects.
Expectation of Privacy
The expectation of privacy is the right an individual has to a certain level of privacy in certain
locations. Most of the time, expectation of privacy is all about an individual inside their place of
residence. For example, a person walking down a public street should of no expectation of
privacy because they are out in the open where anyone can see. However, someone inside
their home with their room changing their clothes has an expectation of privacy from people
taking pictures or looking in through their windows. This expectation of privacy is covered in
many aspects by peeping tom laws that most local and state governments have implemented
to discourage the abuse of others rights. (Kantor, 2008)
Airspace, What You Own
Mandated by the FAA, public airspace starts between 500 and 1000 feet. The discrepancy on
the altitude comes from the term navigable airspace. In accordance to 49 USCS § 401,
navigable airspace is defined as “airspace above the minimum altitudes of flight prescribed by
regulation under this subpart [49 USCS §§ 40101 et seq. 440101 et seq.], including airspace
needed to ensure safety in the takeoff and landing of the aircraft.” (49 USCS § 401) Through
FAA regulations, the FAA has determined the airspace required for safety depends on where
the aircraft is flying. When the aircraft is in the air, the minimum could be 500 feet over
farmland or 1000 plus feet over cities. However, due to United States v. Causby, the

5
homeowner still has air rights as long as their use of the airspace is essential or for the
homeowner’s enjoyment. United States v. Causby was an issue of military vehicles flying over a
Causby’s land, causing his chickens to be scared and become unproductive. Though the court
did rule that the military is legally allowed to do this, they were required to pay restitution to
Causby. (United States v. Causby ET UX., 1946) As more unmanned aerial systems take flight,
this topic what of is owned by the landowner or what is essential to the landowner will become
a more heated issue. In fact, recently in Massachussets, a small community has enacted laws
that made it illegal for the Federal Aviation Administration to lower the public airspace ceiling.
(City of Northampton, 2013) The FAA is considering lowering the altitude requirement due to
the increased use of commercial and civilian unmanned aerial systems. The law that
Northampton passed is in the hopes of instilling ownership of the airspace above landowners.
The major problem that will come up is twofold. First, one who owns the air above them may
give some a sense of privacy from the new flying vehicles, but it does not stop someone from
hovering a craft 30 feet in the air, no more than 30 feet from their abode. Second, national
airspace is regulated at a federal level, this small town may have drawn lines in the sand, but
will eventually be overturned.
Governments View of Expectationsof Privacy
The government can be exempt from expectations of privacy rule on a case by case scenario.
The reason for the exemption usually involves law enforcement. They have a certain amount of
leeway when it comes to invading someone’s privacy, but they must get a warrant first. There
are many laws and court cases upholding the government’s ability to monitor individuals on a
case by case scenario. (Kantor, 2008)
Currently, there are no widespread cases of local law enforcement implementing the use of
unmanned aerial vehicles. Though many law enforcement agencies have purchased unmanned
aerial vehicles, the outcry from civilians has been overwhelming. New technology has pushed
the envelope and as of right now, it seems as though society is not ready for the big-brother
feel of a panopticon society.
Government’s Rightto See Pictures obtained by others
“Law enforcement officials….cannot confiscate your equipment without a court order or if they
are placing you under arrest. Neither can they destroy your property – and that includes
deleting images or exposing film – without a court’s permission.” (Kantor, 2008) While taking
pictures of public property, on public property, or on private property made available to the
public, everyone is in their legal right to take pictures without fearing consequence. These
pictures that have been taken by an individual are in every aspect, the individual’s property,
digitally or with regular film. The issue comes to a crux at the time the individual begins to
share these pictures with anyone else. Based on court rulings in the 1970’s, once any
documentation has been transferred between two parties, there is no expectation of privacy at

6
that moment. So when one put the pictures are posted on Facebook, announced on Twitter, or
placed Imgur, those pictures are no longer allowed to be exempt from an expectation of
privacy. The individual has shared the pictures with another entity, the website used, and can
be privy to the government. (United States v. Miller, 1976)
Legislation
First Amendment
“Congress shall make no law respecting an establishment of religion, or prohibiting the free
exercise thereof; or abridging the freedom of speech, or of the press, or the right of the people
peaceably to assemble, and to petition the Government of redress of grievances.” (U.S. Const.
amend 1)
The First Amendment is brought into this document to give a base level of what is to be
expected for most American citizens. The particular parts of the First Amendment that will be
addressed will be the freedom of speech and the freedom of press. Speech does is not
necessarily a means of communication, but also of expression, including art. Photography is a
form of art and therefore it is protected by the First Amendment. Freedom of press is brought
up because the press and journalism use photography to document events and, therefore,
photography within a journalistic view, is protected by the First Amendment.
Fourth Amendment
“The rights of the people to be secure in their persons, houses, papers, and effects, against
unreasonable searches and seizures, shall not be violated, and no Warrants shall issue, but
upon probable cause supported by Oath or affirmation, and particularly describing the place to
be searched, and the persons or things to be seized. “
The Fourth Amendment is brought into this document to give an understanding on what most
American’s have concerning their rights to privacy. The right to privacy has been amended
within the Fourth Amendment to give citizens a level of expectation of privacy. The right to
privacy has been affirmed and amended by many court proceedings. As mentioned in this
document, expectations of privacy is an issue that is a hot topic. There are questions that arise
that will be addressed later on in this document concerning how to protect oneself against
infringing on others rights. The Fourth Amendment has also been brought up because it
concerns papers and effects, which include documents and information that an individual might
have, digitally or physically. (U.S. Const, amend 2)
USA PatriotAct,
The USA Patriot Act was a piece legislation that was passed in the early 2000’s to help combat
the growing threat of sophisticated terrorism within the United States. In Title II of the Patriot
Act, which is titled Enhanced Surveillance Procedures, the breadth of what is to be allowed via

7
wiretaps and surveillance was widened to include packet switched networks. The Enhanced
Surveillance Procedures were implemented so that the monitoring of internet traffic can be
legally obtained. The Foreign Intelligence Surveillance Act of 1978 created a court that will be
further known as the FISA Court. The Patriot Act amended what the FISA Court was privy to
oversee and was granted the ability to monitor what information was obtained by the
wiretapping the internet. The National Security Agency was then created as the leading
governmental body to monitor the internet traffic. The internet in all it aspects, is considered
to be a foreign body, and therefore all internet traffic can be monitored and collected by the
National Security Agency. The FISA Court has a frequent review of a reoccurring warrant,
allowing the National Security Agency to continue to collect data unabated. The USA Patriot
Act is documented here so that it can give a clear view of what is obtained on the internet and
passed between parties, so that it is known that anything passed through the internet, is no
longer given a reasonable expectation of privacy. The information passed includes emails,
searches, pictures, videos, and anything digital passed along. (USA Patriot Act)
Federal Aviation Administration
The Federal Aviation Administration is the governmental body that monitors and regulates all
air travel. With respect to unmanned aerial vehicles, the Federal Aviation Administration
currently has a few regulations involving unmanned aerial vehicles. As the governing body of
all US airspace, they have the right to regulate all vehicles that are above the ground, whether it
be an inch or 20,000 feet. Generally speaking there is an advisory that most recreational
unmanned pilots must follow, Advisory Circular 91-57. The rules within Advisory Circular 91-57
were created to help with recreational model airplanes and have been assumed to include all
unmanned aerial vehicles. In 2007, the Federal Aviation Administration issued a Federal
Register Notice that mandated the use of unmanned aerial systems cannot be used for
commercial purposes without obtaining approval. Commercial use must file to receive a
Certificate of Waiver or Authorization. (FAA, 2014)
Historical Court Rulings
Nussenzweig v. diCorcia 2007
While walking on the street in New York, Ermo Nussenzweig and had his picture taken by a
photographer, who then used the picture and made it into an art piece. He then sold the
artwork for upwards of 20 to 30 thousand dollars. Mr. Nussenzwig believed that his privacy
and religious rights were violated when the incident happened. He sued diCorcia thereafter. At
the end of the case, it was ruled that the photograph was art, not commerce, and protected by
the First Amendment. (Erno Nussenzweig v. Philip-Lorca diCorcia, 2007)

8
Kyllov. United States 2001
In the early 1990’s a federal law enforcement agent became suspect of a possible marijuana
plant house that was inside Danny Kyllo’s house. When growing marijuana inside a house,
there needs be an excessive amount of light provided by heat lamps. At night, the agent used
an Agema Thermovision 210 Thermal Imager to scan his residence. The imager converted the
infrared radiation coming off the house and was able to detect a large amount of heat coming
from the individual’s roof over the garage. To disprove any thoughts of doubt with the court,
he then also scanned surrounding houses and showed that the roofs of those buildings gave off
no noticeable heat signatures. From the image provided and an excessive power bill, the agent
was then able to obtain a justifiable warrant and raid the residence. The court upheld that this
sort of view was legal. The home was radiating heat passively and the agent used a passive
monitor that collected the infrared radiation. The court then goes on to say that it does not
cover active monitoring. (Kyllo v. United States, 2001)
SmithV. Maryland
In 1976, a woman was robbed in Baltimore Maryland, however, she was able to give a
description of the robber and his getaway vehicle. Shortly after the robbery the victim received
many threatening phone calls from the robber. From the description of the man, the police had
ascertained whom the suspect was. The police then asked the local phone company to keep a
record of all the phone calls coming from the suspect’s house. After some time, they were able
to recognize that the suspect was, in fact, the one calling the victim. During the trial, the
defendant put in a motion to suppress that evidence because it was a violation of his Fourth
Amendment right. The court affirmed that “there is no constitutionally protected reasonable
expectation of privacy in the numbers dialed into a telephone system.” The Supreme Appeals
Court upheld the ruling and granted Certiorari to resolve indications of conflicts within other
courts handling the same issues. Smith v. Maryland is brought up in this document because
communication companies in the digital age deal with a communication between different
parties involving zeros and ones. So far, the case law provided from the ruling has been upheld
and the court’s ruling can function in the digital until further court proceedings take on the
digital age and its issues with privacy. (Smith v. Maryland, 1979)

9
Challenges and Recommendations
Based on the information above in this document, certain challenges arise that need to be
addressed. The challenges and recommendations section will bring up questions and answers
for recommendations..
Issues Involving Unmanned AerialSystems
Issues brought using an unmanned aerial system are pretty straight forward.
 When can I use an unmanned aerial vehicle?
 Is there a regulating body that governs use?
 Where can I use an unmanned aerial system?
 How do I obtain a Certificate of Waiver or Authorization?
 Is there any rulings that the Federal Aviation Administration currently are working on to
allow for more ease of access?
Recommendations and Answers for Flight
A website by the name of know before you fly (www.knowbeforeyoufly.org) has developed a
list of wonderful facts and a cheat sheet that all recreational flyers attempting to fly an
unmanned aerial vehicle should follow. This list of rules and website is recommended by the
Federal Aviation Administration. The list of rules they have are mainly obtained from Advisory
Article 91-57. The rules govern that flight should be no higher than 400 feet, keeping the
unmanned aerial systemin view at all time, remain clear of any manned aircraft, and do not fly
over unprotected persons or moving vehicles. The list then goes on to give ensure that nobody
uses any unmanned aerial systemwhile under the influence of drugs or alcohol, while adverse
weather conditions are imminent, or over sensitive infrastructures such as government
facilities, utility stations, or heavily traveled roadways. While flying within 5 miles of an airport,
permission must be granted by the air traffic controllers of that airport. (Federal Aviation
Administration, 1981)
The regulating body that governs all flight travel is the Federal Aviation Administration. As said
above, they have full authority over all airways above the United States. As the busiest airways
in the world, the Federal Aviation Administration takes their job incredibly seriously and has
very strict rules that cannot be broken. Doing so could result in the revocation of pilot’s
licenses and very expensive fines. The Federal Aviation Administration has been granted these
powers by United States Governments and has been given these powers to maintain a safe and
prosperous use of airways. With the knowledge provided, it is recommended that all persons
using unmanned aerial systems, business or personal, keep themselves abreast of current and
upcoming laws and regulations the Federal Aviation Administration sets forth. Failing to do so
will cause serious consequence.
Public entities are generally the only way, currently, to obtain a Certificate of Authorizations.
Public entities include public colleges, public programs, military, federal and state agencies, and

10
law enforcement agencies. Any flights operations must be conducted for governmental
functions. A civil operation can obtain a Certificate of Authorization, but if the operation is not
a public entity or functions for a public entity, the chances of gaining a certificate is quite low.
When applying for a certificate, certain information needs to be gathered when applying. The
certificate will need to have the exact airspace the unmanned aerial system will be flying in,
specific aircrafts that will be flown, and times of flight. Deviation from these explicitly set rules
will result in possible revocation of the certificate, fines, or loss of licenses.
There is a proposal currently that has been issued out by the Federal Aviation Administration.
The proposal makes some changes to current regulations and implements other regulations
that give clear distinction on what allowed. The proposal is very similar to the current
regulations of Advisory 91-57 in many aspects. The proposal keeps a maximum altitude but
increases 500 feet. It also regulates the operations based on the difference airspace sections,
letting some require air traffic control permission and others not. They also proposed a
requirement for a new operator certification, allowing for operators of unmanned aerial
systems to operate unmanned aerial systems without having to have a pilot’s license. The
proposal also will be addressing the navigable airspace issue that was addressed above as it
pertains to homeowners and unmanned aerial system operators. The proposal plans on
lowering the navigable airspace requirements for flight to anything above the ground. The only
regulation for any airspace except for A class, will be that the limit of altitude is set at 500 feet.
(FAA, 2015)
Issues Involving Cameras on Unmanned Aerial Systems?
This section will give questions that might come up that when flying drones and wanting to take
pictures or capture film.
 What can they take pictures of?
 What is considered private?
 What can an individual do with the captured data from sensors aboard an unmanned
aerial system?
Recommendations for Camera Use While in Flight
While in flight, taking pictures is a matter of where the unmanned aerial systemis and what the
pictures are being taken. As long as the pictures are used for an artistic use or for a journalistic
use, then it is legally allowed. The flights already have to be planned in national airspace, so
based on Nussenzweig v. diCorcia a photographer can take pictures of anything that is easily
visible. Easily visible can be a touchy subject. Up until recently, having a vehicle in the air to be
able to take photographs from a higher vantage point is a new concept. A higher vantage point
could see into windows and over walls. Individuals behind windows or behind open air walls,
can and will, have a reasonable expectation of privacy. So it is recommended that individuals

11
and corporations exercise extreme caution as to not infringe on others rights or legal action
may be taken against the photographer.
While employing other types of sensors on the unmanned aerial system the problems that arise
can be a little tricky. While it has been shown by Kyllo v. United States that using sensors that
detect passive electromagnetic frequencies can be used to filmobjects and persons because it
is freely visible. It is recommended that the use of active sensors be handled on a case-by-case
scenario. It is strongly recommended to use common sense when using it on others without
their permission. If they are in public plain view, there is no reasonable expectation of privacy.
However, using an active sensor can see past clothing or walls, possibly violating privacy.
Therefore, it is strongly recommended to obtain permission of the owners of objects or the
persons that are being monitored by such equipment since their right may be violated if no
consent is given.
The Rightsof a Photographers after the Picture is Taken
This section is not meant as a warning or a commentary on the government. Based on all
current court rulings and legislation, the United States government has all legal rights explained
above and below. The information provided is meant to inform the photographer of what is to
be expected so that they may know what are and aren’t their rights.
Post 9/11 the rights of individuals and businesses have become somewhat blurred with respect
to the Fourth Amendment. The time before the attack on 9/11, the government had legal right
to monitor the numbers punched into telephones and were allowed to keep those for record.
This was not an invasion of privacy because it is shared information between two parties and,
therefore, no reasonable expectation of privacy was to be expected. However, with the digital
age, all information is coming and going at blinding fast speeds, with just two numbers, zero’s
and ones. It can be assumed based on the court case Smith V. Maryland that the government
has all legal rights to monitor such activity and hold it for record, but had no reasonable way of
collecting and keeping that information. After 9/11, the government created a government
agency, National Security Agency, and gave the agency a set of processes on how and what to
collect with respect to the digital age.
With this knowledge, it is recommended by all photographers, that when a picture, film, or
anything digital, is shared, it can and may be collected by the government. This is brought up in
this article because of the growing trend of internet picture sharing websites. The document
addresses this so that the reader may be well informed before taking any pictures or videos,
aerial and on the ground. This way they may have no expectation of privacy when it comes
sharing any information digitally.

12
Conclusion
Though there are many solutions involving unmanned aerial vehicles, photography, and
information, most have explicitly sets of rules and regulations set. These rules are set by
government legislation and by case law. With this knowledge, it is of high importance that the
photographer or aviator keep a working knowledge of regulations and proposed regulations.
Following all applicable local, state, and federal laws will keep the photographer or aviator from
making mistakes that might cause-consequence. It will protect them from possible civil action,
possible fines, or even jail in the event of negligent or criminal activity.
Websites
These are recommended websites to follow so that photographers and unmanned aerial
system aviator can keep abreast of current laws and regulations. Some of the websites
frequently change especially governmental sites, due to the nature of democracy. It is
suggested to visit these websites so that current laws or regulations are not broken.
www.faa.gov
www.knowbeforeyoufly.org
www.aclu.org
www.digitalcameraworld.com
www.dronelaw.net
www.drone-laws.com

13
References
49 USCS § 401. (n.d.).
ACLU. (2014, July). KnowYourRights: Photographers.RetrievedfromACLU:www.aclu.org/kyr-photo
Cityof Northampton.(2013, July11). Resolution on DroneAircraft. RetrievedfromNorthamptonMA:
http://www.northamptonma.gov/DocumentCenter/View/1103
DJI,I. (2015). Phantom2Fact Sheet.RetrievedfromDJIInnovations:
http://www.dji.com/product/phantom-2/spec
Drone-Laws.(2015). Drone-Laws.RetrievedfromDrone-Laws:www.drone-laws.com
Erno Nussenzweigv.Philip-LorcadiCorcia,38A.D.3d 339 (AppellateDivisionof the Supreme Courtof the
State of NewYork,FirstDepartmentMarch 20, 2007).
FAA.(2014, March 07). Busting MythsabouttheFAA and Unmanned Aircraft.RetrievedfromFAA:
www.faa.gov/news/updates/?newsid=76240
FAA.(2015). Overviewof SmallUASNotice of Proposed Rulemaking.Retrieved fromOverview of Small
UAS Notice of ProposedRulemaking:
www.faa.gov/regulations_policies/ruelmaking/media/021515_suas_summary.pdf
Federal AviationAdministration.(1981, June 9).AdvisoryCircular91-57. Model AircraftOperating
Standards.
Kantor,A. (2008). Legal rights of photographers.
KnowBefore YouFly.(2015). Recreation Users.RetrievedfromKnow Before YouFly:
www.knowbeforeyoufly.org
Kochinke,C.(2015). DroneLaw. RetrievedfromDrone Law:www.dronelaw.net
Kyllov.UnitedStates,533 US 27 (Supreme CourtJune 11, 2001).
Manning,M. L. (2010). Less thanPicture Perfect:The Legal RelationshipbetweenPhotographer'sRights
and Law Enforcement. TenneseeLaw Review,Vol78, 58.
Meyer,J. (2012, April 14). PhotographersRights:theultimateguide.RetrievedfromDigital Camera
World:www.digitalcameraworld.com/2012/04/14/photographers-rights-the-ultimate-guide/
Smithv.Maryland, 442 U.S. 735 (Supreme Courtof UnitedStatesJune 20,1979).
UnitedStatesv.CausbyET UX., 328 U.S. 256 (1946) (Supreme Courtof UnitedStatesMay 27, 1946).
UnitedStatesv.Miller,425 US 435 (Supreme CourtApril 21,1976).

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