This case involved the general public's right to film or photograph New York City police officers. In 1973, the NYCLU filed a class action lawsuit on behalf of a group of journalists and citizens called Black v. Codd that determined that filming or photographing officers was not a cause for arrest. In 1977, the city entered into a consent decree with the NYCLU that specifically acknowledged that individuals remain free to photograph police activity, even in circumstances where the police are effecting an arrest, so long as the photograph does not “directly endanger” an :officer or another person.” The terms of this decree were incorporated into the NYPD Patrol Guide.

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