Some or all works by this author are in the public domain in the United States because they were legally published within the United States (or the United Nations Headquarters in New York subject to Section 7 of the United States Headquarters Agreement) between 1923 and 1977 (inclusive) without a copyright notice.

The author died in 1972, so works by this author are also in the public domain in countries and areas where the copyright term is the author's life plus 30 years or less. Works by this author may also be in the public domain in countries and areas with longer native copyright terms that apply the rule of the shorter term to foreign works.