But the stereotypical Peeping Tom has evolved, investigators say, from predators drilling holes in walls or lurking outside windows with binoculars, to infrared cameras hidden in the tip of a shoe.
That evolution was demonstrated in December, when 28-year-old Edward Wainwright was arrested in Omaha after police say he videotaped an undressed 16-year-old girl in a tanning booth.
Wainwright pleaded no contest to unlawful invasion. He was sentenced to five days in jail and 18 months probation, and was told he could not possess a camera.
It wasn't an unusual incident, said Sgt. Scott Christensen of the Nebraska State Patrol. He's worked with two local cases involving candid cameras.
"How many cases are going on that we don't know about — people that just haven't been caught?" said Christensen, a cyber-crimes expert who tracks what he calls the evolution of the Peeping Tom.
"The only difference is technology is changed now," he said. "They're using infrared cameras."
Cameras that can fit in a smoke detector or the tip of a shoe can produce clear, quality video. And they're within many people's price range, some as cheap as $99, said Matt Schott of Jasa Investigative Services of Omaha.
"The general public can purchase this through any catalog," he said.
Cell phone cameras have made surreptitious photographing even easier. A person ostensibly typing a text message on a cell phone may actually be taking pictures.
As a result, many health clubs don't allow cell phones in the locker rooms.
Christensen said pictures sometimes end up on the Internet on sites full of photos taken up women's skirts or down their blouses.
"They even have one called 'church up skirts,' trying to market the fact that these are pictures of girls — of women — in church settings," Christensen said.
Christensen said even if Peeping Toms are caught, they often face only misdemeanor charges, which carry little or no jail time.
The 16-year-old victim at the tanning salon said she still feels violated. She's scared to use the restroom or even try on clothes at a store.
"You just realize how gross people are, and how far they'll go to get what they want," the girl said.