The North Carolina Court of Appeals has upheld the convictions of Patrick Junior Havens for secret peeping and sexual exploitation of a minor. The court's decision, filed on June 17, 2026, affects Havens, who was sentenced to a total of 31 to 107 months in prison for his crimes. This case highlights the serious nature of offenses involving the exploitation of minors and the legal ramifications that follow such actions.
Havens was found guilty of secret peeping, second-degree sexual exploitation of a minor, and third-degree sexual exploitation of a minor. The court's ruling reinforces the importance of protecting minors from such predatory behavior, especially within familial settings. The case began when a 13-year-old girl, referred to as S.H., discovered hidden cameras in her grandparents' bathroom, leading to a police investigation that uncovered troubling evidence against Havens.
Background
The case originated in Lincoln County, where S.H. moved in with her grandparents, including defendant Patrick Junior Havens. On March 26, 2023, S.H. sought permission from Havens to use the nicer bathroom in their home. After receiving permission, she discovered two devices disguised as charging blocks that were actually cameras recording her without consent.
Upon realizing the cameras were recording, S.H. removed them and later contacted her sister about the incident. When law enforcement arrived, S.H. reported her findings, leading to a search warrant being executed at the home. During the investigation, police found numerous images and videos of S.H. in various states of undress, taken without her knowledge.
The Ruling
The Court of Appeals, led by Judge Valerie Zachary, affirmed the trial court's decision, stating that there was sufficient evidence to support the jury's verdict. The court ruled that the evidence presented demonstrated that Havens acted with the intent to capture images of S.H. without her consent. The court noted, "Defendant installed charging block cameras in more than one bathroom, and of the approximately 100,000 images and multiple videos on each camera, Defendant selectively recorded on his cell phone only those videos showing S.H. in various degrees of nudity."
The court also addressed Havens' argument regarding the lack of intent to invade S.H.'s privacy, clarifying that the law does not require proof of intent to invade privacy for the charge of secret peeping. The court stated, "The State was simply required to prove that Defendant secretly or surreptitiously used or installed the charging block cameras in a room."
Impact
This ruling has significant implications for cases involving the exploitation of minors, particularly regarding the use of technology to invade privacy. The court's affirmation of Havens' convictions sends a clear message about the seriousness of such offenses and the legal consequences that perpetrators may face. It reinforces the legal protections in place to safeguard minors from exploitation, particularly in situations where trust is violated within family dynamics.
The decision also serves as a precedent for similar cases, emphasizing that the intent to invade privacy may not be necessary to prove secret peeping, as long as the act of recording without consent is established. This could lead to stricter scrutiny of cases involving hidden cameras and other surveillance devices used inappropriately.
What's Next
Havens has the option to appeal the ruling to a higher court, although details regarding any pending related cases were not available in the court filing. The outcome of this case may influence future legal interpretations of privacy laws and the protection of minors in North Carolina and beyond.