A U.S. patent was issued for cycling reheated water in a washing machine, to Hamilton E. Smith of Philadelphia, Pennsylvania (No. 21,909). His invention was an improvement for washing machines in which a reciprocating plunger acts on clothes in a tub. His invention placed two horizontal diaphragms in the tub. Both moved vertically with the action of the plunger. The upper one was perforated, and the lower one had a valve. Below the lower diaphragm springs pushed it up as the plunger was lifted. Their motion acted to pump water into the tub from a circuit of pipe that included coils in a heating tank and drained cooler water from the top of the tub. Smith improved his machine and obtained a second patent in 1863.

President George W. Bush signed the USA Patriot Act which expands the authority of U.S. law enforcement agencies for the stated purpose of fighting terrorism in the United States and abroad. by giving them additional ability to search, seize, or eavesdrop telephone, e-mail communications, medical, financial and other records in their pursuit of possible terrorists.