In a case in which defendant was convicted, inter alia, on one count of open and gross lewdness, he argued unsuccessfully that NRS 201.210 was void for vagueness. The Nevada Supreme Court ruled that the term open was not vague, as used in § 201.210, gross sufficiently informed people what degree of lewdness was prohibited, and the terms lewd or lewdness had generally accepted meanings. Berry v. State, 125 Nev. 265, 212 P.3d 1085, 125 Nev. Adv. Rep. 26, 2009 Nev. LEXIS 34 (Nev. 2009).