Future Unclear For NSA's Bulk Telephone Metadata Collection Program

Fast approaching is the June 1 expiration of certain provisions of the Patriot Act, including § 215 (codified as 50 U.S.C § 1861), which is the basis for the National Security Agency's (NSA) bulk telephone metadata collection program (the "telephone metadata program").  The future of the program is unclear in light of ACLU, et al. v. Clapper, et al., a recent Second Circuit decision that struck down the program as illegal under § 215, and the continued turmoil in Congress regarding efforts to reform or renew the Patriot Act. In ACLU v. Clapper, the Second Circuit overturned the district court's dismissal of ACLU's complaint, ruling that the NSA's telephone metadata program was illegal under § 215.  The program first came to light in 2013 after former government contractor Edward Snowden leaked documents exposing its details to a British newspaper.  The NSA has since admitted that the program has been in place since at least May 2006.  Under the program, numerous