MEMORANDUM
To: Assistant District Attorney William Blake
From: Rebecca Pollock/Paralegal
Date: November 12, 2018
RE: Susan Williams and Invasion of Personal Privacy
FACTS
On 5/8/2018 Joseph Scum, DOB 4/18/1975, was discovered by Target store security to have
taken pictures of Susan Williams, DOB 6/5/2005, without her consent. The pictures taken were
of a personal privacy matter. Mr. Scum walked up to Susan Williams, pretended he needed to tie
his shoe, and quickly used his phone to take a picture under the girl’s dress. The store security
immediately left his CCTV booth and confronted Mr. Scum. He escorted Mr. Scum to the
security office and took the phone where he discovered the picture taken under the dress of the
girl. The photo clearly showed the black underwear of the girl under her dress. The store
security personnel then located the girl and her mother and explained what had occurred. Both
said they wanted to ensure that Mr. Scum was prosecuted. Franklin County Sherriff’s office was
contracted and placed Mr. Scum under arrest for violation of ORS 163.700.
QUESTIONS PRESENTED
1. Did Mr. Scum violate ORS 163.700 by knowingly taking a photograph of Susan
Williams in a state of nudity without her consent?
2. Was the photograph taken in a place where Susan Williams had a reasonable expectation
of personal privacy?
3. Did Mr. Scum take the photograph for the purpose of arousing or gratifying sexual desire
without Susan’s consent?
4. Did Mr. Scum take the photograph in a public place?
5. Did Mr. Scum violate the personal privacy of Susan Williams?
SHORT ANSWERS
1. Mr. Scum did violate ORS 163.700 by knowingly taking a photograph of Susan Williams
in a state of nudity without her consent.
2. The photograph was taken in a place where Susan Williams had a reasonable expectation
of personal privacy.
3. Mr. Scum may have taken the photograph with the purpose of arousing or gratifying
sexual desire without Susan’s consent.
4. Mr. Scum did take the photograph in a public place.
5. Mr. Scum violated the personal privacy of Susan Williams.
DISCUSSION
Mr. Scum took the photograph without the girl’s consent. He took the photograph in a public
place. Mr. Scum admitted to the Franklin County Sheriff Deputy that he did take the photograph
and stated, “that he was sick and that he needed help”. Susan Williams and her mother decided
to press charges of invasion of personal privacy.
CONCLUSION
Mr. Scum violated the rights of Susan Williams by taking a photograph under the girl’s dress
without her consent which is an invasion of personal privacy.
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