California v. Lyon
Annotate this CaseDefendant Michael Lyon was found guilty by jury of six counts of eavesdropping on or recording confidential communications, and two counts of disorderly conduct. These counts arose from defendant's secret videotaping of prostitutes at his residence. Defendant argued on appeal that prostitutes, as a matter of law, have no reasonable expectation of privacy in their communications during sexual encounters at a client’s residence, and therefore the trial court erred in denying his motion to dismiss on those grounds. He further contended reversal was required due to instructional error, unlawful prosecution under the "Williamson" rule, and an unlawful probation search. Finding no reversible error, the Court of Appeal affirmed defendant's convictions.
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