Ohio
Ohio Voyeurism and Hidden Camera Laws: Offenses, Penalties, and Protections
Independently fact-checked against primary sources (last audited November 1, 2026). · Reviewed by the RecordingLaw editorial team. · Law checked current as of November 1, 2026. · 7 primary sources cited on this page. How we verify our legal content
Ohio prohibits voyeurism under ORC 2907.08, which bars secretly recording a person in a place where they have a reasonable expectation of privacy to view their private areas, secretly recording under or through clothing anywhere, and spying on someone for sexual gratification. Penalties range from a third-degree misdemeanor for basic peeping to a fifth-degree felony when the victim is a minor, and every conviction carries mandatory sex offender registration.
Quick Answer
Ohio criminalizes voyeurism through ORC 2907.08, which prohibits secretly recording someone in a place where they have a reasonable expectation of privacy to view their private areas, and spying on someone for sexual gratification. Penalties range from a third-degree misdemeanor for basic peeping offenses to a fifth-degree felony for recording minors. All voyeurism convictions in Ohio require registration as a sex offender. Ohio also criminalizes nonconsensual dissemination of private sexual images under ORC 2917.211.
Ohio Voyeurism Statute: ORC 2907.08
Division (A): Spying and Eavesdropping for Sexual Gratification
The first category of voyeurism under ORC 2907.08 covers traditional "peeping Tom" behavior. It is illegal to:
- Trespass on property or surreptitiously invade the privacy of another person
- Spy upon or eavesdrop upon another person
- Do so for the purpose of sexually arousing or gratifying yourself
This division covers the act of watching someone without their knowledge for sexual purposes. The offender does not need to use a camera or recording device. Simply watching through a window, peephole, or other opening is enough to trigger this offense.
Classification: Third-degree misdemeanor Maximum penalty: 60 days in jail and a $500 fine
Division (B): Secret Recording in Private Places
Division (B) addresses technology-assisted voyeurism. It is illegal to:
- Secretly or surreptitiously videotape, film, photograph, broadcast, stream, or otherwise record another person
- In a place where the person has a reasonable expectation of privacy
- For the purpose of viewing the private areas of that person
This division specifically targets hidden cameras in bathrooms, bedrooms, locker rooms, changing areas, hotel rooms, and any other private space. The statute covers all forms of visual recording, including still photography, video, live streaming, and broadcasting.
Classification: Second-degree misdemeanor Maximum penalty: 90 days in jail and a $750 fine
Division (C): Recording Minors in Private Places
Division (C) elevates the offense when the victim is a minor. It is illegal to commit any of the acts described in Division (B) when the victim is under 18 years of age.
Recording a minor in a place where a person has a reasonable expectation of privacy, for the purpose of viewing the private areas of the minor, is treated as a felony, reflecting the heightened concern for child safety.
Classification: Fifth-degree felony Maximum penalty: 6 to 12 months in prison and a $2,500 fine
Division (D): Upskirting and Recording Under Clothing
Division (D) specifically addresses "upskirting" and "downblousing." It is illegal to:
- Secretly or surreptitiously videotape, film, photograph, or otherwise record another person
- Above, under, or through the clothing being worn by that other person
- For the purpose of viewing the body of, or the undergarments worn by, that other person
This offense can occur in any location, public or private. Recording under someone's skirt in a grocery store, at a park, or at a workplace all fall under this division. The location does not need to be private.
Classification: First-degree misdemeanor Maximum penalty: 180 days in jail and a $1,000 fine
Penalty Summary Table
| Offense | ORC Division | Classification | Max Jail/Prison | Max Fine |
|---|---|---|---|---|
| Spying for sexual gratification | 2907.08(A) | M3 misdemeanor | 60 days | $500 |
| Secret recording in private place | 2907.08(B) | M2 misdemeanor | 90 days | $750 |
| Recording a minor in private place | 2907.08(C) | F5 felony | 6-12 months prison | $2,500 |
| Recording under/through clothing | 2907.08(D) | M1 misdemeanor | 180 days | $1,000 |
Enhanced Penalties for Repeat Offenders
Ohio's voyeurism statute itself does not include a repeat-offender enhancement; the classification for each division in the table above is fixed regardless of prior convictions. Other offenses covered on this page do escalate for repeat conduct, including nonconsensual image dissemination under ORC 2917.211 and menacing by stalking under ORC 2903.211. An offender with a prior sex-offense conviction can be placed in a higher registration tier.
Sex Offender Registration
Mandatory Registration for All Voyeurism Convictions
One of the most significant consequences of a voyeurism conviction in Ohio is mandatory sex offender registration. Under Ohio's sex offender registration laws (ORC Chapter 2950), all individuals convicted of voyeurism must register with the local sheriff's office.
Registration requirements include:
- Providing name, address, date of birth, social security number, and photograph
- Reporting employment and school enrollment information
- Updating registration information when any details change
- Complying with address verification requirements
Registration Tiers
Ohio uses a tier system for sex offenders:
- Tier I: Registration for 15 years with annual address verification
- Tier II: Registration for 25 years with semi-annual address verification
- Tier III: Lifetime registration with quarterly address verification
Every voyeurism conviction under ORC 2907.08 is a Tier I offense under ORC 2950.01(E), whether it is a misdemeanor or the felony for a minor victim. The court has no discretion over that tier, and a higher tier generally requires a prior sex-offense conviction.
Impact of Sex Offender Registration
Sex offender registration carries severe collateral consequences:
- Public listing on the Ohio Attorney General's eSORN database
- A ban on living within 1,000 feet of school premises, preschool or child care center premises, children's crisis care facility premises, or residential infant care center premises (ORC 2950.034)
- Employment limitations in jobs involving children or vulnerable adults
- Community notification, but only for Tier III offenders, which a voyeurism conviction alone does not produce
- Travel restrictions and reporting obligations
- Difficulty finding housing
Hidden Camera Offenses
Common Hidden Camera Scenarios
Ohio law enforcement has prosecuted hidden camera cases involving:
- Rental properties: Landlords hiding cameras in tenant bathrooms or bedrooms
- Bathrooms and restrooms: Cameras concealed in public restrooms, store bathrooms, and portable toilets
- Locker rooms: Cameras in gym, pool, or workplace locker rooms
- Hotel rooms: Hidden cameras placed by property owners or previous guests
- Workplaces: Cameras in employee changing areas or private offices
- Homes: Hidden cameras placed by partners, roommates, or household members
Detection and Reporting
If you discover a hidden camera:
- Do not touch or remove the device (preserve evidence for law enforcement)
- Take photographs of the camera and its location
- Contact local police immediately
- Note the type of device, its position, and how it was concealed
- Identify potential suspects who had access to the location
Technology Used in Hidden Cameras
Modern hidden cameras come in many disguises:
- Smoke detector cameras
- Clock cameras
- USB charger cameras
- Mirror cameras
- Pen cameras
- Screw and bolt cameras
- Air freshener cameras
- Motion detector cameras
The small size and low cost of modern cameras make detection more challenging. Victims can use RF detectors, infrared scanners, or professional sweep services to check for hidden devices.
Nonconsensual Dissemination of Private Sexual Images: ORC 2917.211
What the Law Prohibits
ORC 2917.211 makes it a crime to share intimate images of another person without their consent. The statute was enacted in 2019 and was significantly updated by House Bill 96, with enhanced penalties effective September 30, 2025.
To violate this law, the prosecution must prove:
- The defendant knowingly disseminated an image
- The victim is 18 or older
- The image depicted the victim in a state of nudity or engaged in a sexual act
- The victim did not consent to the dissemination
- The victim is identifiable from the image itself, or from identifying information displayed with it that the defendant supplied
- The defendant shared the image with intent to harm the victim
Criminal Penalties
| Offense | Classification | Penalty |
|---|---|---|
| First offense | Fifth-degree felony | 6-12 months prison, up to $2,500 fine |
| Second offense or prior sex offense | Fourth-degree felony | 6-18 months prison, up to $5,000 fine |
Fabricated (Deepfake) Sexual Images
Ohio updated ORC 2917.211 to address AI-generated and digitally fabricated sexual images. The statute now includes:
- Division (C): Knowingly sharing a fabricated sexual image of another person without their consent is a fourth-degree felony. No intent to harm is required.
- Division (D): Creating a fabricated sexual image, or asking someone to create one, without the depicted person's consent is a fourth-degree felony when it is done with intent to distribute the image and in order to harass, extort, threaten, or cause physical, emotional, reputational, or economic harm to that person.
Both offenses were added by House Bill 96, effective September 30, 2025. Each carries 6 to 18 months in prison and fines up to $5,000, and rises to a third-degree felony if the offender has a prior conviction under this section or for a sexually oriented or child-victim oriented offense.
Civil Remedies
Under ORC 2307.66, victims of nonconsensual image dissemination can file civil lawsuits seeking:
- Injunctions and restraining orders to stop further dissemination
- Compensatory damages for emotional distress, reputational harm, and other losses
- Punitive damages
- Attorney fees and litigation costs
Federal Law: The TAKE IT DOWN Act
The TAKE IT DOWN Act, signed into law May 19, 2025, creates a parallel federal framework for nonconsensual intimate images. It criminalizes knowingly publishing or threatening to publish nonconsensual intimate images, including AI-generated deepfakes depicting real people. Covered online platforms must remove content within 48 hours of receiving a victim's notice request. The platform removal obligation is effective May 19, 2026. Victims of nonconsensual intimate image abuse can pursue both Ohio ORC 2917.211 state charges and federal charges under this Act.
Exceptions
The statute does not apply to:
- Images shared for a lawful criminal investigation
- Images shared to report unlawful conduct
- News reports, commentary, and artistic or expressive works
- Images shared by law enforcement or corrections officers within their official duties
- Images shared for another lawful public purpose
- Images of an adult who was knowingly and willingly nude or engaged in a sexual act in a place without a reasonable expectation of privacy
- Images shared for medical treatment or examination
Intersection with Other Ohio Laws
Wiretapping Law: ORC 2933.52
Voyeurism and hidden camera offenses often overlap with wiretapping violations. If a hidden camera records audio in addition to video, the offender faces separate charges under ORC 2933.52 for illegal interception of communications. This is a fourth-degree felony carrying 6 to 18 months in prison.
A single hidden camera with audio in a bathroom could result in:
- Voyeurism charges under ORC 2907.08 (misdemeanor or felony depending on the victim)
- Wiretapping charges under ORC 2933.52 (fourth-degree felony)
- Sex offender registration
Menacing by Stalking: ORC 2903.211
If hidden camera placement is part of a pattern of stalking behavior, the offender may also face charges under ORC 2903.211. Stalking is a first-degree misdemeanor that can be elevated to a fourth-degree felony for repeat offenders.
Telecommunications Harassment: ORC 2917.21
Distributing hidden camera recordings to harass the victim can trigger additional charges under ORC 2917.21 for telecommunications harassment.
Federal Charges
In some cases, hidden camera and voyeurism offenses can result in federal charges:
- 18 U.S.C. 1801: Federal video voyeurism statute, which applies only within the special maritime and territorial jurisdiction of the United States, such as federal enclaves
- Child exploitation charges if the victim is a minor and images are transmitted across state lines
Victims' Rights and Resources
Reporting Voyeurism
Victims should:
- Contact local law enforcement immediately
- Preserve any evidence (do not delete messages or images)
- Document the timeline of events
- Request a protective order if needed
- Contact a victim advocacy organization for support
Ohio Victim Resources
- Ohio Attorney General's Crime Victim Services
- Ohio Civil Rights Commission
- Ohio Alliance to End Sexual Violence
- National Domestic Violence Hotline: 1-800-799-7233
- Cyber Civil Rights Initiative: for revenge porn victims
Protective Orders
Ohio courts can issue civil protection orders (CPOs) that prohibit the offender from:
- Contacting or approaching the victim
- Disseminating any images of the victim
- Coming within a specified distance of the victim's home, workplace, or school
- Possessing the victim's images or recordings
Violating a CPO is a criminal offense that can result in arrest and additional charges.
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Frequently Asked Questions
What is the penalty for voyeurism in Ohio?
Penalties range from a third-degree misdemeanor (60 days jail, $500 fine) for basic peeping to a fifth-degree felony (6-12 months prison, $2,500 fine) for recording a minor. All voyeurism convictions require sex offender registration in Ohio.
Is upskirting illegal in Ohio?
Yes. ORC 2907.08(D) specifically prohibits secretly or surreptitiously recording above, under, or through someone's clothing to view their body or undergarments, anywhere, including in public. This is a first-degree misdemeanor carrying up to 180 days in jail and a $1,000 fine, plus mandatory sex offender registration.
Is revenge porn illegal in Ohio?
Yes. ORC 2917.211 makes nonconsensual dissemination of private sexual images a fifth-degree felony on the first offense (6-12 months prison, $2,500 fine) and a fourth-degree felony for repeat offenders. The law also covers AI-generated deepfake images.
Do I have to register as a sex offender for voyeurism in Ohio?
Yes. Ohio requires sex offender registration for all voyeurism convictions under ORC 2907.08, regardless of whether the offense is classified as a misdemeanor or felony. Registration duration depends on the tier classification, ranging from 15 years to lifetime.
What should I do if I find a hidden camera?
Do not touch or remove the device. Take photographs of the camera and its location, then contact local police immediately. Preserve all evidence for law enforcement. You may also have civil remedies including injunctions and damages against the person who placed the camera.
Updates
Replaced an open-ended description of Ohio's sex-offender residency restriction with the statute's list of covered premises.
We corrected this page to say that Ohio's voyeurism recording offenses require no sexual motive, listed the full elements and exceptions of the intimate-image law, clarified the separate sharing and creation offenses for fabricated sexual images added in 2025, and fixed the sex offender registration details (every voyeurism conviction is Tier I, community notification is Tier III only, and the residency ban does not list playgrounds).
Independently fact-checked against the cited primary sources; governing law re-checked for recent changes
Corrected the description of Ohio's voyeurism statute, ORC 2907.08, so the purpose element of divisions (B) and (C) and the clothing language of division (D) match the current statutory text.
Independently fact-checked against the cited primary sources; governing law re-checked for recent changes
Governing law re-checked for recent changes
Corrected the first-offense felony degree for fabricated (deepfake) sexual images under ORC 2917.211(C)-(D) from F5 to F4 (matching the statute and the article's own later section), and removed an unsupported claim that Ohio's voyeurism statute (ORC 2907.08) itself escalates penalties for repeat offenders.
Governing law re-checked for recent changes
Reviewed and approved by an editor
The Law Behind This Article
This article rests on the statutory provisions below, held in our own legal record and retrieved from the official source. Tap a section to read the operative text.
Ohio Revised Code
§ 2907.08VoyeurismIn forcecited in 14 of our articles
(A) No person, for the purpose of sexually arousing or gratifying the person's self, shall commit trespass or otherwise surreptitiously invade the privacy of another, to spy or eavesdrop upon another.
Official text (excerpt) · last checked 2026-07-31 · Read the full text in our law library · Verify at codes.ohio.gov
Cited in 97 court opinions in our collectionLatest citing opinion in our collection: 2026
In the courts (editorial summary, independently checked):Ohio courts have applied R.C. 2907.08 to conduct concealed from the victim. State v. Sipple (2021) held the state need not prove an image was actually captured to sustain an attempted-voyeurism conviction. State v. Goldblum (2014) held that acts committed while the victims slept satisfied the surreptitious-invasion element.
Opinions citing this section in our collection:
- State v. Sipple (Ohio Court of Appeals 2021, 170 N.E.3d 1273)✓Sipple put his phone under a woman's dress at an event without her knowledge. The court affirmed his attempted voyeurism conviction under R.C. 2907.08(D), holding the state need not prove a photo was taken and that stealth without her authority was surreptitious.
- State v. Goldblum (Ohio Court of Appeals 2014, 2014 Ohio 5068)✓Goldblum lifted the covers and clothing off girls sleeping at his home and stared at their genitals. Affirming convictions under R.C. 2907.08(C), the court held acts done while the victims slept surreptitiously invaded their privacy and that sexual purpose could be inferred.
- State v. Huffman (Ohio Court of Appeals 2006, 165 Ohio App. 3d 518)✓Huffman hid wireless cameras in his tanning salon rooms and recorded patrons, including a minor. Affirming convictions under R.C. 2907.08(B) and (C), the court held digital video is a series of photographs, so recording video counted as photographing under the statute.
Identified automatically from the court opinions citing this section — not a ranking of which case controls.
Also relied on in: Ohio Smart Glasses Recording Laws: One-Party Consent Guide, Ohio Recording Laws (2026): One-Party Consent Rules, Ohio Audio Recording Laws: Consent, Devices, and Penalties
§ 2307.66Civil action for dissemination of imagesIn forcecited in 4 of our articles
(A) A victim of a violation of section 2917.211 of the Revised Code has and may commence a civil cause of action against the offender for any of the following, in addition to reasonable attorney's fees and the costs of bringing the civil action: (1) An injunction or a temporary restraining order…
Official text (excerpt) · last checked 2026-07-31 · Read the full text in our law library · Verify at codes.ohio.gov
Also relied on in: Ohio Deepfake Laws: AI Images, Voice Cloning & Penalties (2026), Ohio Sexting Laws: Legal Consequences and Penalties
§ 2903.211Menacing by stalkingIn forcecited in 7 of our articles
(A)(1) No person by engaging in a pattern of conduct shall knowingly cause another person to believe that the offender will cause physical harm to the other person or a family or household member of the other person or cause mental distress to the other person or a family or household member of the…
Official text (excerpt) · last checked 2026-07-31 · Read the full text in our law library · Verify at codes.ohio.gov
Cited in 666 court opinions in our collectionLatest citing opinion in our collection: 2026
Opinions citing this section in our collection:
- State v. Fry (Ohio Supreme Court 2010, 125 Ohio St. 3d 163)“…nderlying felony enhancements to the charge. {¶ 126} R.C. 2903.211 defines menacing by stalking:…”
- State v. Tichon (Ohio Court of Appeals 1995, 102 Ohio App. 3d 758)“…ally require psychiatric treatment.” *763 R.C. 2903.211(A) states that “[n]o person by engaging…”
- State v. Spaulding (Slip Opinion) (Ohio Supreme Court 2016, 2016 Ohio 8126)“…e that he would cause her physical harm or mental distress. R.C. 2903.211(A)(1). Accordingly, as explained below…”
Identified automatically from the court opinions citing this section — not a ranking of which case controls.
Also relied on in: Ohio Laws on Recording in Public: Rights, Limits, and Privacy, Ohio Security Camera Laws: Residential, Commercial, and Privacy Rules, Ohio Video Recording Laws: Public Filming, Privacy, and Penalties
§ 2917.21Telecommunications harassmentIn force
(A) No person shall knowingly make or cause to be made a telecommunication, or knowingly permit a telecommunication to be made from a telecommunications device under the person's control, to another, if the caller does any of the following: (1) Makes the telecommunication with purpose to harass,…
Official text (excerpt) · last checked 2026-07-31 · Read the full text in our law library · Verify at codes.ohio.gov
Cited in 267 court opinions in our collectionLatest citing opinion in our collection: 2026
Opinions citing this section in our collection:
- City of Cleveland Heights v. Lewis (Ohio Supreme Court 2011, 129 Ohio St. 3d 389)“…2915.02(F) and 2915.03(B)), telecommunications harassment (R.C. 2917.21(C)(2)), and election falsification (R.C…”
- State v. Wagner (Ohio Court of Appeals 1992, 80 Ohio App. 3d 88)“…Clermont County Court for telephone harassment pursuant to R.C. 2917.21(B). The record indicates that' a…”
- State v. Powell (Ohio Court of Appeals 2020, 2020 Ohio 4283)“…viction for telecommunications harassment, in violation of R.C. 2917.21(B)(1). Because her conviction wa…”
Identified automatically from the court opinions citing this section — not a ranking of which case controls.
§ 2917.211Dissemination of image of another personIn forcecited in 9 of our articles
(A) As used in this section: (1) "Child-victim oriented offense" and "sexually oriented offense" have the same meanings as in section 2950.01 of the Revised Code.
Official text (excerpt) · last checked 2026-07-31 · Read the full text in our law library · Verify at codes.ohio.gov
Cited in 5 court opinions in our collectionLatest citing opinion in our collection: 2026
In the courts (editorial summary, independently checked):Ohio's Fifth District Court of Appeals has twice found the evidence sufficient under this section for person-to-person sends. State v. Allison (2021) upheld a conviction where nude photographs of the victim were texted to her daughter, and State v. Gilmore (2024) did the same where nude images of an ex-girlfriend were emailed.
Opinions citing this section in our collection:
- State v. Hudson (Ohio Court of Appeals 2022, 2022 Ohio 3253)“…ssemination of private sexual images, each in violation of R.C. 2917.211, misdemeanors of the second degree. The…”
- State v. Gilmore (Ohio Court of Appeals 2024, 2024 Ohio 2095)✓A man emailed nude and sexually explicit photos of his ex-girlfriend to her brother-in-law with taunting messages after she refused to reconcile; the court held the evidence sufficient on the elements of R.C. 2917.211 and affirmed the conviction.
- State v. Bradley (Ohio Court of Appeals 2026, 2026 Ohio 232)✓After a breakup, a man stalked his ex, broke into her home, and sent nude photos and a video of her to her new boyfriend; the court held the R.C. 2917.211(B) dissemination count was committed separately from the stalking counts, so the offenses did not merge.
Identified automatically from the court opinions citing this section — not a ranking of which case controls.
Also relied on in: Ohio Pornography Laws (2026): Legal Status and the AV Loophole, Revenge Porn Laws by State: All 50 States and DC (2026)
§ 2933.52Interception of wire, oral or electronic communicationsIn forcecited in 19 of our articles
(A) No person purposely shall do any of the following: (1) Intercept, attempt to intercept, or procure another person to intercept or attempt to intercept a wire, oral, or electronic communication; (2) Use, attempt to use, or procure another person to use or attempt to use an interception device to…
Official text (excerpt) · last checked 2026-07-31 · Read the full text in our law library · Verify at codes.ohio.gov
Cited in 64 court opinions in our collectionLatest citing opinion in our collection: 2025
In the courts (editorial summary, independently checked):State v. Bidinost (1994) held R.C. 2933.52(A)'s ban on purposeful interception applies to cordless telephone conversations intercepted and recorded on a baby monitor, requiring suppression. State v. Childs (2000) held the party seeking to suppress bears the burden of proving a 2933.52(A)(1) violation.
Opinions citing this section in our collection:
- State v. Robb (Ohio Supreme Court 2000, 88 Ohio St. 3d 59)✓During a prison siege, FBI agents used tunnel microphones to record rioting inmates' conversations without a warrant; the court held those interceptions were exempt under former Section 2933.52(B)(1), Ohio's exception for interceptions made under federal wiretap law.
- State v. Childs (Ohio Supreme Court 2000, 88 Ohio St. 3d 558)✓A defendant sought to suppress tapes of her own conversations as intercepted in violation of Section 2933.52(A)(1), but no one proved whether the other party consented; the court held the party seeking suppression carries the burden of proof, so the motion failed.
- State v. Bidinost (Ohio Supreme Court 1994, 71 Ohio St. 3d 449)✓A neighbor's baby monitor began picking up the defendant's cordless phone calls, and at police direction she recorded them; the court held that was a purposeful interception barred by Section 2933.52(A) and that the recordings had to be suppressed.
Identified automatically from the court opinions citing this section — not a ranking of which case controls.
Also relied on in: Ohio Dashcam Laws: Mounting Rules, Audio Recording, and Evidence, Ohio Landlord-Tenant Recording Laws: Privacy, Cameras, and Rights, Ohio Medical Recording Laws: Patient Rights, HIPAA, and Consent
United States Code Title 18
§ 1801Video voyeurismIn forcecited in 81 of our articles
Whoever, in the special maritime and territorial jurisdiction of the United States, has the intent to capture an image of a private area of an individual without their consent, and knowingly does so under circumstances in which the individual has a reasonable expectation of privacy, shall be fined under this title or imprisoned not more than one year, or both. In this section— the term “capture”, with respect to an image, means to videotape, photograph, film, record by any means, or broadcast; the term “broadcast” means to electronically transmit a visual image with the intent that it be viewed by a person or persons; the term “a private area of the individual” means the naked or undergarment clad genitals, pubic area, buttocks, or female breast of that individual; the term “female breast” means any portion of the female breast below the top of the areola; and the term “under circumstances in which that individual has a reasonable expectation of privacy” means— circumstances in which a reasonable person would believe that he or she could disrobe in privacy, without being concerned that an image of a private area of the individual was being captured; or circumstances in which a…
Official text (excerpt) · last checked 2026-07-28 · Read the full text in our law library · Verify at uscode.house.gov
Cited in 53 court opinions in our collectionLatest citing opinion in our collection: 2026
In the courts (editorial summary, independently checked):Courts have applied 18 U.S.C. 1801 mainly at its edges. United States v. Johnson (2010) read it as Congress's answer to secretly filming nudity on federal property, acquitting on a child exploitation charge instead. EPIC v. Department of Homeland Security (2011) applied the Section 1801(c) law enforcement exception to a TSA scanner claim.
Opinions citing this section in our collection:
- United States v. Anthony Helton (Court of Appeals for the Fourth Circuit 2019, 944 F.3d 198)“…from this list of federal offenses is video voyeurism under 18 U.S.C. § 1801. Rather than list this statute as an enu…”
- United States v. Johnson (District Court, W.D. Missouri 2010, 719 F. Supp. 2d 1059)✓A weightlifting coach hid a camera to film minors weighing in nude; acquitting him under the child exploitation statute, the court called that conduct plain video voyeurism under section 1801, but noted the section reaches only federal maritime and territorial jurisdiction.
- Electronic Privacy Information Center v. United States Department of Homeland Security (Court of Appeals for the D.C. Circuit 2011, 653 F.3d 1)✓Privacy groups challenged TSA body scanners under the Video Voyeurism Prevention Act; the D.C. Circuit held the statute's exception for lawful law enforcement, correctional, or intelligence activity applied to airport screening, so the section 1801 claim failed.
Identified automatically from the court opinions citing this section — not a ranking of which case controls.
Also relied on in: Is It Illegal to Video Record Someone Without Their Consent? (2026), California Voyeurism and Hidden Camera Laws: Penalties and Protections (2026), Delaware Voyeurism Laws: Hidden Cameras, Penalties, and Privacy Protections (2026)
Explore the law
This article also draws on these acts and chapters (opening at their first section): Ohio Revised Code § 2950.01 (Definitions)
Related law for further reading — not part of this article’s citations.
Sources and References
- Ohio Rev. Code 2907.08 - Voyeurism(codes.ohio.gov).gov
- Ohio Rev. Code 2917.211 - Nonconsensual dissemination of private sexual images(codes.ohio.gov).gov
- Ohio Rev. Code 2307.66 - Civil action for nonconsensual image dissemination(codes.ohio.gov).gov
- Ohio Rev. Code Chapter 2950 - Sex offender registration(codes.ohio.gov).gov
- Ohio Rev. Code 2933.52 - Interception of wire, oral, or electronic communications(codes.ohio.gov).gov
- Ohio Rev. Code 2903.211 - Menacing by stalking(codes.ohio.gov).gov
- Ohio Attorney General - Crime Victim Services(ohioattorneygeneral.gov).gov
- 18 U.S.C. 1801 - Federal video voyeurism statute(law.cornell.edu)