On May 28, 2002, the United States Court of Appeals for the Seventh Circuit affirmed the holding of the United States District Court for the Central District of Illinois and the defendant's conviction.

On October 18, 2001, the Illinois Supreme Court, on direct appeal, reversed the circuit court, holding that the Hospital Licensing Act, 210 ILCS 85/6.17, did not violate the separation of powers doctrine, did not unreasonably violate a patient's right to privacy, and did not constitute impermissible special legislation.

Knowingly videotaping or photographing persons in locker rooms, changing rooms, or hotel bedrooms will soon be a Class A misdemeanor under a new amendment to the Criminal Code.

On January 13, 2000, the First Division of the Appellate Court of Illinois, reversed in part the circuit court of Cook County's judgment in favor of Kmart Corporation.

On January 4, 1999, the first district of the Illinois Appellate Court affirmed the holding of the Circuit Court of Cook County, finding that the plaintiff had not satisfied his invasion of privacy claim.