State v. Pallman
In State v. Pallman, 5 Conn. Cir. Ct. 202, 248 A.2d 589, 590 (Conn. Cir. Ct. 1968), a Connecticut court upheld a conviction for indecent exposure where the defendant, who had been dispatched by his employer to repair a pump at an apartment, exposed himself to a nine-year-old boy in the bathroom of a private dwelling. On appeal, the defendant argued that "the state 'failed to prove that he ... exposed himself in a public place or that he exposed himself in a private place where he was seen by more than one person or could have been seen by more than one person had he or she looked.'" Id.
The Connecticut statute proscribed wanton and indecent exposure, but the statute did not include a "public place" requirement.
Therefore, the Connecticut court ruled: "It is enough if it be an intentional act of exposure, offensive to one or more persons. To hold otherwise would be to hold that one might commit with impunity any act of indecency, however gross, before any number of individuals successively." Id. at 592.