PDAs a Crime?

(That's Public Displays of Affection, for those worried about their Palm Pilots.)

In Colorado, Connecticut, Illinois, and Nebraska, public "lewd fondling" is a crime akin to public nudity. Under the Kansas decision I note below, would public French kissing by two consenting adults qualify? Or would it only be considered "lewd touching" (the rubric under which the Kansas court categorized French kissing) rather than "lewd fondling"?

Remember, "public kissing is a public nuisance." (The only person I can credit for this is Carrie DuShey, though I don't know if she's the author.)