Rose v. Locke, 423 U.S. 48 (1975), was a United States Supreme Court case in which a Tennessee statute proscribing "crime against nature" was held not unconstitutionally vague as applied to cunnilingus, satisfying as it does the due process standard of giving sufficient warning that men may so conduct themselves as to avoid that which is forbidden.

Moreover, the Tennessee Supreme Court by previously rejecting claims that the statute was to be narrowly applied has given sufficiently clear notice that it would be held applicable to acts such as those involved here when such a case as this arose.

[2][better source needed] Locke appealed his conviction on the basis that the statutory term "crimes against nature" could not "in and of itself withstand a charge of unconstitutional vagueness" and being unable to find any Tennessee opinion previously applying the statute to the act of cunnilingus.

As early as 1955, Tennessee had expressly rejected a claim that "crime against nature" did not cover fellatio, repudiating those jurisdictions which had taken a narrow and restrictive definition of the offense.

Specifically: [T]he Florida courts had repeatedly and explicitly ruled that the state law in question prohibited precisely the conduct in which the defendants were found to have engaged.