Simpson v. Simpson
490 F.2d 803
In the United States Court of Appeals for the Fifth Circuit
Case Number 73-1521
Before Circuit Judge Bell, Circuit Judge Coleman, and Circuit Judge Roney
Decided on March 08, 1974

Relevancy of the Case: Validity of wire interception provisions and federal claims arising thereof in marital disputes

Statutes and Provisions Involved

• The Omnibus Crime Control and Safe Streets Act, 18 U.S.C. §§ 2510-2520

Relevant Facts of the Case

• The present case involves a wife (plaintiff) and her husband (defendant). The main issue is the husband’s interception of the wife’s communication with a third party in their marital home.
• The husband obtained a recording device for tapping and recording telephone conversations. He recorded his wife’s conversations with another man. These conversations were mildly compromising, establishing that the other man was making advances. He thereafter played these recordings or parts thereof to various neighbours and family members.
• On a lawyer’s advice, the wife agreed to an uncontested divorce. After the divorce, she brought the present action before the District Court. When her claim failed, she appealed, stating that her claim has constitutional protections of privacy.

Opinion of the Bench

• Congress did not intend to include marital home and domestic conflicts in the statute’s scope. Subsection (5)(a)(i) of Section 2510 also covers this point.
• The primary goal of the statute is to control crimes. When construing a criminal statute, the court should avoid any behaviour that has not been clearly prescribed.
• The locus in quo does not extend beyond the parties’ marital home, so it does not create a federal cause of action against the former husband.

Final Decision

• The court affirmed the District Court’s decision.

Upama Nandy, an undergraduate student at Symbiosis Law School, Pune, prepared this case summary during her internship with The Cyber Blog India in January/February 2023.