State v. Chiles
In State v. Chiles, 53 Wn. App. 452, 767 P.2d 597 (Wash. Ct. App. 1989), the court considered whether the defendant's indecent exposure in his home, in front of a window from which he was visible to pedestrians walking on the public sidewalk, constituted conduct in a "public place" within the meaning of the statute then in effect. Id. at 597.
The court said, id. at 599:
"Indecent exposure at common law consists of exposure in public of the entire person or of parts that should not be exhibited. Exposure is in a public place if it occurs at a place open or exposed to the view of the public. The public place provision of the common law offense is not inconsistent with the statute. Here, the record clearly establishes that the defendant indecently exposed his person to the view of passersby walking along a public thoroughfare. These facts satisfy the statutory requirement of former RCW 9A.88.010, as interpreted by Sayler, that the indecent exposure must occur in a public place."