IntroductionUnmanned aerial systems (UAS) popularly known as "drones" have a long history dating back to World War I as remotely controlled aerial targets according to Howeth (1963) . However, their current role in surveillance is much shorter. Unmanned aircraft are predominantly used by the military in surveillance and precision strike roles. Advances in military UAS programs and the signing of the FAA Modernization and Reform Act of 2012 have facilitated the need to formulate a plan to regulate unmanned aircraft operating over the United States. This study will address the main concern expressed by the public regarding law enforcement's use of unmanned aerial vehicles to track people and collect evidence. What are the current laws governing law enforcement use of unmanned aerial vehicles? There have been several legal cases involving aerial surveillance, only one using unmanned aerial vehicles, State v. Brossart (2012). This limits the UAS data, but provides a reasonable platform on which to base the study. Helicopters or manned aircraft that use cameras to conduct surveillance are conducting the same surveillance that an unmanned aircraft would, as Molko (2013) addresses in his research. Detailed debates have occurred across the country regarding the Fourth Amendment and whether our privacy will be lost once unmanned aircraft are given permission to fly in the National Airspace System (NAS) over the United States. A particular public concern is that law enforcement uses unmanned aircraft for surveillance. According to the National Conference on State Legislation (2013), “In 2013, 43 states introduced 130 bills and resolutions addressing UAS issues.” The FAA has imposed restrictions on the use of unmanned aircraft regarding safety and limitations on paper. February 1, 2012. Accessed May 3, 2014. http://www.gpo.gov/fdsys/pkg/CRPT-112hrpt381/pdf/CRPT-112hrpt381.pdf."FAA selects six sites for unmanned aircraft research." FAA Selects Six Sites for Unmanned Aircraft Research December 30, 2013. Accessed May 3, 2014. http://www.faa.gov/news/updates/?newsId=75399.Howeth, Linwood S. "Howeth: Chapter XL (1963)." Howeth: Chapter XL (1963). 1963. Accessed May 2, 2014. http://earlyradiohistory.us/1963hw40.htm.Molko, Robert. 2013. The drones are coming! WILL THE FOURTH AMENDMENT STOP THE THREAT TO OUR PRIVACY? Brooklyn Law Review 78, no. 4: 1279-1333."Statutes of the State." 1PGA. Accessed May 3, 2014. http://www.1gpa.org/statutes.php."State v. Brossart." July 31, 2012. Accessed May 3, 2014. https://www.nacdl.org/uploadedFiles/files/news_and_the_champion/DDIC/Brossart%20Order.pdf.