Photographing below skirt not unlawful.

Phoyographing nude or semi nude is unlawful. But a woman in skirt is neiother nude nor smi nude. So nothing wrong in photographing her below the skirt. So ruled the court. But the legislators are not okay with the court ruling. So they are changing law.

https://www.bostonglobe.com/2014/03/05/mass-high-court-says-upskirting-legal-under-state-law/9kN0dd4DQGWJCyi5rddQXN/story.html

http://www.bostonglobe.com/opinion/editorials/1969/12/13/upskirting-embarrassment-finally-motivates-beacon-hill-act/7BQs0ZBtgAmZLE1y29CLdO/story.html