Just a few days before people were performing fellatio in the streets of San Francisco, New York City's famed Naked Cowboy was arrested in Union Square. Sporting a cowboy hat, a guitar, and some "skin-tight underpants" (hey, that's technically not naked!), Robert Burck was picked up by SFPD for "performing his act in a restricted area." Burck, according to reports, was ticked for violating "rules posted in Union Square against soliciting and playing an instrument."(Whew. Way to keep the streets of SF safe, SFPD!) Burck is due in court today.