 In 1985, upon returning to the issue of grand jury indictments in the case of "United States v. Miller" (1985), the Court decided on a somewhat looser interpretation of the Fifth Amendment requirements as set forth in Bain.Now, modifications to a grand jury indictments, if only to reduce charges, make simple changes, or remove text, are allowed.Bain has been overruled in part by "United States v. Cotton", 535 U.S. 625 (2002).