Medium: Performance in front of Mizuno Gallery, Los Angeles
Date: Nov. 12, 1972

In this piece, Burden positioned himself behind the rear wheels of a parked car in front of Mizuno Gallery on La Cienega Boulevard, a busy street in L.A. "At 8 p.m. I lay down on La Cienega Boulevard and was covered completely with a canvas tarpaulin," Burden said after the event. "Two fifteen-minute flares were placed near me to alert cars. Just before the flares extinguished, a police car arrived. I was arrested and booked for causing a false emergency to be reported." Burden's trial was held in Beverly Hills and his case was eventually dismissed when the jury failed to reach a decision.