Does anyone have any case law or other helpful authority that says the "date of the commission of the offense" for improper photography is the day it was discovered?

It seems to me that otherwise, if a victim does not discover that they have been improperly photographed until after the three-year SOL has run, then the offender just gets to walk away. But I can't find any authority to the contrary.

Does the Discovery Rule even apply to criminal cases like it does with civil cases?

I've never heard anything that says it would, but this forum is always helpful in coming up with nuances I've never heard of.

There are ways to stretch the date for things left theft and fraud, but this may be something we need to talk about extending the SOL for in the future as Improper Photography becomes more prolific on account of cell phone cameras.

There is no discovery rule in criminal cases like there is in civil cases. The date of the crime controls.