On May 7, 2015, the U.S. Second Circuit Court of Appeals (the Court) ruled [3] in ACLU v. Clapper that the National Security Agency (NSA) bulk metadata telephone collection program is unlawful.  The Court found that “the district court erred in ruling that § 215 [of the USA PATRIOT Act] authorizes the telephone metadata collection program, and instead hold that the telephone metadata program exceeds the scope of what Congress has authorized and therefore violates § 215.”  Because the Court ruled that the program exceeds the scope of what Congress authorized, the Court “dismiss[ed] the complaint without reaching appellants’ constitutional arguments.” According to a news article [4], the “decision voided a December 2013 ruling in which U.S. District Judge William Pauley in Manhattan found the NSA program lawful. The appeals court sent the case back to him for further review.”