California Private Investigator

The Tragedy That Changed Federal Laws of Open Source Information and Created the Driver’s Privacy Protection Act.

Every parent’s worst nightmare arrived by telephone on July 18, 1989 — a call no father should ever receive.  Rebecca Schaeffer was a 21-year-old actress widely recognized for her role on the CBS sitcom My Sister Sam — a rising talent whose face was familiar to millions of American households. I was already inside this profession — already pulling records, already locating people — when the story unfolded of how an obsessed fan hired a private investigator to obtain her home address through an open California DMV record, walked to her front door, and shot her. She was not the first. Actress Theresa Saldana, known for her role in I Wanna Hold Your Hand and the TV series We Got It Made, had survived a nearly identical attack in 1982 — her attacker also hired a private investigator to pull her address from DMV records. The profession had seen this before and done nothing. That moment did not land as breaking news. It landed as a professional reckoning. I have been a California Private Investigator since 2000, with roots in this industry going back to 1996, and what I know about permissible purpose laws I did not learn from a compliance manual. I know why they were written because I watched the tragedy that made them necessary. These are not bureaucratic hurdles or inconvenient workarounds invented to complicate how investigators get paid. They were drawn in response to a young woman’s murder. They prevent people from getting killed. What I have seen unfold in history has shaped every decision Stryker Investigation Services makes about who we serve, what we access, and where we draw the line.

The Investigator Who Ran the Search Anyway

There is a question that has sat in the margins of the Rebecca Schaeffer case for over three decades, largely unasked in the public narrative and conspicuously absent from the legislative record that followed: What was the private investigator thinking?

Not the legal question. The human one.

Robert John Bardo was not a difficult read. He was a 19-year-old unemployed janitor who had previously worked at a Jack in the Box and had a documented fixation on a celebrity he had never met, spending three years sending her letters, attempting to visit her on set, and consuming every piece of public information available about her life. 

The firm that ran the search was the Anthony Agency, a private investigative firm in Tucson, Arizona. Robert John Bardo paid them approximately $250 to $300 and told them he was an old friend who wanted to send Schaeffer a gift. He produced a signed 8-by-10 publicity photo as proof of the relationship. That was the due diligence. A fan photo and a fabricated story. Agency manager Anthony Zinkus later testified that Bardo had presented himself as a friend. Employee William Johnson stated that requests like Bardo’s were routine — common among people trying to locate relatives or friends. The Anthony Agency maintained after the murder that they had been deceived. That may be true. But a signed publicity photo from a fan is not evidence of friendship — it is evidence of obsession. Any working California Private Investigator who has spent time screening locate requests knows the difference. The Anthony Agency either did not know, did not ask, or did not care. In 1989 there was no law requiring them to do otherwise. There was only professional judgment. They substituted it for a transaction.

A structured client intake — a series of direct queries designed to identify, document, and assess potential  stalking behavior — would have surfaced the red flags immediately:

• Has the subject consented to being located?
• What is your relationship to the subject?
• What is the intended use of the address once obtained?
• Have you had prior contact with this individual?
• Has the subject taken any steps to limit their public accessibility?

These are not invasive questions. They are the minimum threshold of professional responsibility when the deliverable is a human being’s physical location. An unlisted home address requested by an unknown third party with no documented legal purpose and no client relationship to any proceeding is not a routine locate — it is a warning.

The motive was almost certainly money. A $250 to $300 cash transaction with no accountability, no permissible purpose requirement, no paper trail, and no consequences — at least none that existed under the law at that time. The legal architecture that would have compelled a different outcome simply did not yet exist. That is precisely why it had to be built.

What I have seen unfold in history has shaped every decision Stryker Investigation Services makes about who we serve, what we access, and where we draw the line. Operating in this industry since 1996 and licensed since 2000, the standard this firm holds is not negotiable: a retainer does not suspend good judgment or common sense. The client intake process is not a courtesy. It is a professional firewall. When the indicators of obsessive, unwanted, or threatening fixation are present in a locate request, the answer is not to run the search. The answer is to decline — and in cases where the threat assessment rises to a credible level of danger, the answer may well be to pick up the phone and call law enforcement.

Rebecca Schaeffer did not have the protection of a law that required that standard. She had only the professional conscience of an investigator who chose to cash the check instead.

That choice cost her life.

Bardo was convicted of first-degree murder on October 29, 1991. The case was prosecuted by Marcia Clark — who would later become one of the most recognized names in American legal history as lead prosecutor in the O.J. Simpson murder trial. That two landmark cases of that era passed through the same prosecutor’s hands speaks to the weight both carried inside the Los Angeles justice system and the broader national conversation about celebrity, obsession, and the failure of institutions to protect the vulnerable.

The Legislative Response

Schaeffer’s murder catalyzed three landmark developments that continue to govern investigative practice, privacy rights, and law enforcement investigative tactics  to this day.

1. The Driver’s Privacy Protection Act (DPPA) — 18 U.S.C. § 2721

Enacted as Title XXX of the Violent Crime Control and Law Enforcement Act of 1994, the DPPA is codified at Chapter 123 of Title 18 of the United States Code. The statute prohibits the disclosure of personal information — as defined in 18 U.S.C. § 2725 — without the express consent of the person to whom such information applies, with limited exceptions enumerated in 18 U.S.C. § 2721(b). Wikipedia

Among the permissible uses specifically identified under the statute is use by any licensed private investigative agency or licensed security service for any purpose otherwise permitted under the subsection. Legal Information Institute . This is not a blanket authorization — it is a permissible-purpose framework, and Stryker Investigation Services operates squarely within it. Every DMV inquiry conducted by this firm is executed under a documented permissible purpose tied to a legitimate legal matter, consistent with our obligations under the DPPA, the Gramm-Leach-Bliley Act (GLBA), and the Fair Credit Reporting Act (FCRA).

Violations of the DPPA carry criminal fines under 18 U.S.C. § 2723, and state DMV agencies that maintain a policy or practice of substantial noncompliance are subject to civil penalties imposed by the Attorney General of up to $5,000 per day. NY DMV Private individuals whose records are unlawfully obtained or disclosed retain a civil cause of action under 18 U.S.C. § 2724.

2. California Penal Code § 646.9 — The Nation’s First Anti-Stalking Law

Prior to Schaeffer’s death, there were no anti-stalking laws anywhere in the United States. Inspired by her murder and the deaths of four other women killed despite having restraining orders, California passed its first anti-stalking law in 1990, giving law enforcement greater authority to intervene before violence occurred. The law was subsequently revised and strengthened, codified as California Penal Code § 646.9, which makes it illegal to follow, harass, or threaten someone with the intent of causing them to fear for their safety. Within three years, 30 additional states enacted similar statutes, and today anti-stalking laws exist in all 50 states.

The 1993 revision to PC 646.9 was significant: it broadened the definition of “credible threat” to include implied threats — verbal, written, or established by a pattern of conduct — and it clarified what constitutes “immediate family,” strengthening the prosecutor’s hand considerably.

3. The LAPD Threat Management Unit

The Los Angeles Police Department responded to the post-Schaeffer environment by creating a specialized unit devoted to stalking cases  — the first of its kind in American law enforcement. That unit became the national model for threat assessment and management protocols that agencies across the country now employ.