Clayton v. Richards

ROSS, Justice,

concurring.

Since this case presents an issue of first impression, I believe it helpful to analyze the issue in relation to the established privacy rights developed under the laws, both federal and state, pertaining to wiretapping. For example, federal law prohibits interspousal wiretapping within the marital home. See 18 U.S.C.A. §§ 2510-2513, 2515-2520 (West 2000); Collins v. Collins, 904 S.W.2d 792 (Tex.App.—Houston [1st Dist.] 1995), writ denied per curiam, 923 S.W.2d 569 (Tex.1996); Turner v. PV Int’l Corp., 765 S.W.2d 455 (Tex.App.—Dallas 1988), writ denied per curiam, 778 S.W.2d 865 (Tex.1989); accord Heggy v. Heggy, 944 F.2d 1537 (10th Cir. 1991); Kempf v. Kempf, 868 F.2d 970 (8th Cir.1989); Pritchard v. Pritchard, 732 F.2d 372 (4th Cir.1984); United States v. Jones, 542 F.2d 661 (6th Cir.1976).5 Texas law also prohibits interspousal wiretapping. See Tex.Pen.Code Ann. § 16.02 (Vernon Supp.2001); Duffy v. State, 33 S.W.3d 17, 24 (Tex.App. — El Paso 2000, no pet.); Collins, 904 S.W.2d at 796-97. The act of videotaping a spouse does not meet the technical requirements to come under these prohibitions. See Duffy, 33 S.W.3d at 23; United States v. Torres, 751 F.2d 875, 880 (7th Cir.1984). However, the underlying concern of both the federal and state wiretap statutes was to protect the right of privacy. See Gelbard v. United States, 408 U.S. 41, 48-50, 92 S.Ct. 2357, 33 L.Ed.2d 179 (1972); Collins, 904 S.W.2d at 797. An individual’s right of privacy is compromised no less from being secretly videotaped than from being secretly recorded. A secret videotape of an individual who presumes to be in a private place is an even greater intrusion of privacy than *157secretly recording conversations. Torres, 751 F.2d at 878. Videotapes are a simultaneous audio and visual recording of events. Ali v. State, 742 S.W.2d 749, 754 (Tex. App. — Dallas 1987, writ ref'd).

Cases decided under the federal wiretap statute have found third-party invasions into the marital union to be egregious. “For purposes of federal wiretap law, it makes no difference whether a wiretap is placed on a telephone by a spouse or by a private detective in the spouse’s employ. The end result is the same-the privacy of the unconsenting parties to the intercepted conversation has been invaded.” United States v. Jones, 542 F.2d 661, 670 (6th Cir.1976). Even in the most noted case for an interspousal exception to the federal wiretap statute, the Fifth Circuit stated that “to our minds a third-party intrusion into the marital home, even if instigated by one spouse, is an offense against a spouse’s privacy of much greater magnitude than is personal surveillance by the other spouse.” Simpson v. Simpson, 490 F.2d 803, 809 (5th Cir.1974); see Remington v. Remington, 393 F.Supp. 898 (E.D.Pa.1975).

Based on these authorities, it is clear that married individuals retain rights of privacy, especially against third parties. The concern with these rights is evident from the federal and state wiretap statutes which have no exception for acts between spouses. By logical deduction, it can be reasoned that if unauthorized recording of a telephone conversation by one spouse against the other violates the unconsenting spouse’s right of privacy, then unauthorized videotaping of a spouse’s actions violates the same right of privacy.

. Only two federal circuits have read an inter-spousal exemption from the federal wiretap statute. Anonymous v. Anonymous, 558 F.2d 677 (2d Cir. 1977); Simpson v. Simpson, 490 F.2d 803 (5th Cir. 1974). These opinions have been, widely criticized. See Collins v. Collins, 904 S.W.2d 792, 797 (Tex.App. — Houston [1st Dist.] 1995), writ denied per curiam, 923 S.W.2d 569 (Tex.1996); People v. Otto, 2 Cal.4th 1088, 9 Cal.Rptr.2d 596, 831 P.2d 1178, 1184-90 (1992); Scott J. Glick, Is Your Spouse Taping Your Telephone Calls?: Title III and Interspousal Electronic Surveillance, 41 Cath. U.L.Rev. 845 (1992).