Upskirting is the practice of surreptitiously photographing underneath a female's dress or skirt. Upskirting often occurs by voyeurs who carry small video cameras or cell phones with photo capability in escalators in public places, outdoor parks, and shopping malls. Because upskirting occurs in public places, there is a legal debate over whether the victim is entitled to a reasonable expectation of privacy. Some states and localities have passed laws making it illegal to film or photograph under someone's clothing in a public place. Some state laws, which vary by state, have prohibited video voyeurism, which is defined to include upskirting.