Here's an interesting legal story:

  A Scranton, Pennsylvania, woman who allegedly shouted profanities at her overflowing toilet within earshot of a neighbor was cited for disorderly conduct, authorities said.
  Dawn Herb could face up to 90 days in jail and a fine of up to $300.
  "It doesn't make any sense. I was in my house. It's not like I was outside or drunk," Herb told The Times-Tribune of Scranton. "The toilet was overflowing and leaking down into the kitchen and I was yelling [for my daughter] to get the mop."
  Herb doesn't recall exactly what she said, but she admitted letting more than a few choice words fly near an open bathroom window Thursday night.
  Her next-door neighbor, a city police officer who was off-duty at the time, asked her to keep it down, police said. When she continued, the officer called police.

  So you're wondering, is that really a crime? The answer is 'no, it's not.' Civil libertarians and those with bad bathroom plumbing, rejoice: In Pennsylvania, you can scream at your overflowing john all you want without violating the state's disorderly conduct offense. Here's the text of 18 Pa.C.S. § 5503(a), Pennsylvania's prohibition on disorderly conduct:

A person is guilty of disorderly conduct if, with intent to cause public inconvenience, annoyance or alarm, or recklessly creating a risk thereof, he:
(1) engages in fighting or threatening, or in violent or tumultuous behavior;
(2) makes unreasonable noise;
(3) uses obscene language, or makes an obscene gesture; or
(4) creates a hazardous or physically offensive condition by any act which serves no legitimate purpose of the actor.

  Let's assume that Herb's yelling amounted to "unreasonable noise" or "obscene language." The statute only prohibits such yelling "with intent to cause public inconvenience, annoyance or alarm, or recklessly creating a risk thereof." Did Herb do that? It seems pretty clear she didn't. The word "public" is defined in § 5503(c):

As used in this section the word "public" means affecting or likely to affect persons in a place to which the public or a substantial group has access; among the places included are highways, transport facilities, schools, prisons, apartment houses, places of business or amusement, any neighborhood, or any premises which are open to the public.

  The definition is rather oddly drafted; "neighborhoods" and "apartment houses" have both public and private spaces within them. But Pennsylvania caselaw is clear that the annoyance or incovenience must be that of the general public, not just one or two specific people who happen to be nearby. The Pennsylvania Supreme Court stressed this in an early case involving a man who operated a "go kart" track, Commonwealth v. Greene, 410 Pa. 111 (1963). Use of the track to race go-karts made a lot of noise that apparently annoyed the neighbors, and the operator of the track was then charged with and convicted of disorderly conduct. The Pennsylvania Supreme Court reversed in an opinion by the always-colorful Justice Musmanno:

  The cardinal feature of the crime of disorderly conduct is public unruliness which can or does lead to tumult and disorder. Engaging in clamor and outcry in the public streets in a manner which arouses attention and causes people to draw together, whereby the highway may be obstructed, is the classic example of disorderly conduct. . .
  While noise may break tranquility, upset rest, destroy sleep and fracture serenity, it does not of itself break the public peace, an indispensable feature of the crime of disorderly conduct, when the traveling public is not disturbed. If the production of noise alone made out the crime of disorderly conduct, then the coffers of the Commonwealth and municipalities entitled to monetary returns could be filled with fines assessed and collected from cheering football and baseball fans, riveting hammer operators, gong-clanging street car motormen, airplane pilots, siren-sounding ambulance drivers, missile testers, amusement park devotees, bathroom soloists, fife and drum players, trombone zealots, fireworks enthusiasts, etc. . . .
  The crime of disorderly conduct is not intended as a catchall for every act which annoys or disturbs people; it is not to be used as a dragnet for all the irritations which breed in the ferment of a community.

  Given the plain language of the statute and the Greene decision, I think it's pretty clear that Herb isn't guilty of disorderly conduct. Herb and her daughter were at home, and it sounds like the neighbor was the only one else around. Annoying your neighbor by being really noisy may be inconsiderate. But it's not the crime of disorderly conduct, even if your annoyed neighbor happens to be a police officer. Free Dawn Herb!

  Thanks to Victor Steinbok for the link.