In United States v. Shaffer, 46 M.J. 94 (1997), cert. denied, 522 U.S. 869 (1997), the U.S. Court of Appeals for the Armed Forces addressed a Navy chief petty officer's challenge to his conviction for indecent exposure; the defendant had stood in his open garage while "completely naked." Id. at 96.
The defendant argued that the evidence was not sufficient to support his conviction, however, because the evidence did not establish that his exposure was "wilful." Id.
Upholding the conviction, the court stated:
The fact that appellant's exposures took place in and on his private property is of no particular moment. The offense of indecent exposure does not just apply to exposures that take place on traditionally public lands or in traditionally public buildings. The offense also applies to indecent exposures that occur in places "so public and open," including privately-owned homes, that they are "certain to be observed" by the general population. Id. at 96-97 .