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Koeppel v. Speirs

Iowa Supreme Court
808 N.W.2d 177 (2011)


Facts

Robert Speirs (defendant) installed a hidden camera in an office bathroom. Speirs claimed he originally installed it in the reception area to monitor an employee suspected of misconduct, but saw nothing suspicious and removed it. Then Speirs allegedly found a hypodermic needle near the employee’s parking space and reinstalled the camera in the bathroom. Speirs claimed it did not work and that he disconnected the monitor and receiver. The next day, another employee, Sara Koeppel (plaintiff) discovered the camera. The police found the camera inoperable, with a dead battery. After replacing it and reassembling the receiving equipment, a grainy, foggy image of an officer inside the bathroom appeared only briefly, before a “no signal” message appeared. Koeppel sued Speirs for invasion of privacy. The trial court granted summary judgment for Speirs on the ground that no actual intrusion occurred absent proof that the camera actually worked in the bathroom. The court of appeals reversed, finding sufficient evidence that the camera was operational to survive summary judgment. Speirs appealed to the Iowa Supreme Court.

Rule of Law

Issue

Holding and Reasoning (Cady, C.J.)

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