Missouri
Missouri GPS Tracking Laws: Is It Legal to Put a Tracker on a Car? (2026)
Independently fact-checked against primary sources (last audited June 17, 2026). · Law checked current as of August 9, 2026. How we verify our legal content
Missouri is one of the few remaining states with no criminal statute that directly addresses placing a GPS tracker on someone else's car. A jealous ex, a suspicious spouse, or an obsessive acquaintance who slips a tracker under your bumper has not, by that single act, committed a crime under Missouri law.
That gap surprises most people, and it has real consequences. But "no tracking statute" does not mean "anything goes." Repeated tracking can be charged as stalking, federal law reaches the worst cases, and victims can fight back with protection orders and civil lawsuits.
This guide walks through where the legal lines actually sit in Missouri as of 2026, what lawmakers have and have not passed, the stalking amendments that take effect on July 1, 2027, and what to do if you find a tracker on your vehicle.
Is It Legal to Put a GPS Tracker on a Car in Missouri?
If the car is yours, yes. Missouri places no restrictions on tracking a vehicle you own or lease, even if someone else drives it.
If the car belongs to someone else, the honest answer is uncomfortable: no Missouri statute makes the act of attaching a tracker, by itself, a crime. Prosecutors cannot charge "unlawful tracking" because that offense does not exist in the state.
That does not make secret tracking safe. Entering a locked garage or fenced property to plant the device can be trespass. Using the location data to follow, confront, or intimidate someone can quickly become criminal stalking. And tracking that crosses state lines can trigger the federal stalking statute, 18 U.S.C. 2261A.
Missouri Has No Tracking Device Statute
More than half the states now criminalize installing an electronic tracking device on another person's vehicle without consent. Missouri is not one of them.
Lawmakers know about the gap. Representative Strickler filed HB 1570 in 2024 and HB 293 in 2025, each of which would have created the offense of "unlawful tracking of a motor vehicle," a misdemeanor with felony enhancements for repeat offenses. HB 1911, sponsored by Representative Williams, carried the same offense in the 2026 session: knowingly installing, concealing, or otherwise placing an electronic tracking device in or on a motor vehicle without the consent of all owners, with exceptions for criminal investigations, usage-based insurance programs, parents and guardians, and repossession. None of these bills put that offense into Missouri law.
Missouri did pass tracking-relevant legislation in 2026, and it is easy to miss because it is not a vehicle-tracking bill. SS#2 for SB 999, signed by Governor Kehoe on July 13, 2026, repeals and re-enacts RSMo 565.002, 565.225, and 565.227 so that the stalking statutes expressly reach "technological abuse conduct," a new defined term that names location tracking devices. Those changes take effect on July 1, 2027 and are covered in the stalking section below. They do not create a standalone tracking offense, so the core point stands: there is still no crime called unlawful tracking of a motor vehicle in Missouri.
One point of confusion worth clearing up: some websites claim RSMo 575.205 criminalizes installing trackers. It does not. RSMo 575.205 makes it a class D felony to tamper with electronic monitoring equipment that a court or the parole board has ordered someone to wear. It punishes offenders who cut off their own ankle monitors, not people who plant trackers on cars.
When Tracking Becomes Stalking (RSMo 565.225 and 565.227)
Missouri's stalking laws are the main criminal tool against GPS tracking, and what they say about tracking devices changes on July 1, 2027.
Section C of SS#2 for SB 999 sets that date as the effective date for the re-enacted versions of RSMo 565.002, 565.225, and 565.227. Note that the Missouri Revisor of Statutes now displays the July 1, 2027 text of both stalking sections by default, so a reader who follows a plain section link is reading the future version, not the one in force today.
The law in force through June 30, 2027
Stalking in the second degree (RSMo 565.227) applies when a person purposely, through their course of conduct, disturbs or follows another person with the intent to disturb them. It is a class A misdemeanor, rising to a class E felony for repeat offenders or when the victim is a law enforcement officer.
Stalking in the first degree (RSMo 565.225) adds aggravating factors: making threats, violating an order of protection or release conditions, targeting a victim under 17 when the offender is 21 or older, or having a prior domestic assault conviction against the same victim. It is a class E felony, rising to a class D felony in officer-victim and repeat cases.
The key concept is "course of conduct." RSMo 565.002 defines it as "a pattern of conduct composed of two or more acts, which may include communication by any means, over a period of time, however short, evidencing a continuity of purpose." Planting a tracker, checking its location feed repeatedly, and showing up where the victim goes can satisfy that pattern. That definition is carried forward unchanged into the 2027 version.
The limitation matters, and it now has an expiration date. Because the current statute requires conduct that disturbs the victim, purely covert tracking that the victim never discovers is hard to charge. That is the hole the standalone tracking bills were written to close, and it is the hole the 2027 amendments narrow.
What changes on July 1, 2027
From that date, amended RSMo 565.227 applies when a person knowingly engages in a course of conduct directed at a specific person, or technological abuse conduct, which would cause a reasonable person under the circumstances to feel harassed, terrified, or intimidated. New RSMo 565.002(19) defines technological abuse conduct as an act or pattern of behavior intended to harm, threaten, intimidate, control, stalk, harass, or monitor another person using any form of technology, and the list of examples includes location tracking devices. RSMo 565.225 is rewritten around the same reasonable-person standard.
Two practical consequences follow. Tracking is named in the statutory scheme for the first time, so a prosecutor no longer has to argue that a tracking device fits a definition written without it in mind. And because technological abuse conduct is defined as "an act or pattern of behavior," the amended text is not limited to the two-or-more-acts course of conduct the current version requires. The classifications and maximum penalties do not change, and Missouri still has no standalone vehicle-tracking offense either before or after that date.
Who Can Legally Track a Vehicle in Missouri
Some tracking is clearly lawful in Missouri:
- Owners and co-owners. You can put a tracker on a vehicle titled in your name, including a jointly titled family car.
- Parents and guardians. Tracking a vehicle your minor child drives is a normal exercise of parental authority.
- Employers. Companies can track their own fleet vehicles (more below).
- Lenders and repossession companies. Loan and lease agreements routinely include tracking consent.
- Rental and car-sharing companies. Tracking is disclosed in the rental contract.
- Police with a warrant. In United States v. Jones (2012), the U.S. Supreme Court held that attaching a GPS device to a vehicle and monitoring it is a Fourth Amendment search, so officers generally need a warrant.
The murkiest case is a spouse tracking a car titled only in the other spouse's name. No Missouri statute forbids it, but divorce courts can treat it as harassment, and it can feed a stalking charge or a protection order once the spouse feels disturbed.
Can My Employer Track My Car in Missouri?
Missouri has no statute restricting employer GPS tracking, so the default rules are simple. On a company-owned vehicle, the employer can track essentially without limit, although clear written notice is the industry standard.
Your personal vehicle is different. An employer who hides a tracker on an employee's own car without consent has no statutory shield and invites an invasion of privacy lawsuit, especially for off-duty monitoring. Tracking through a phone app you agreed to install as a condition of work is generally treated as consent.
If your workplace concerns extend to cameras and recorded calls, see our Missouri recording laws guide and our overview of surveillance camera laws.
AirTags and Item Trackers in Missouri
AirTags, Tiles, and similar Bluetooth trackers get the same legal treatment as hardwired GPS units: Missouri has no statute aimed at them. Dropping an AirTag into someone's bag or glove box is not, standing alone, a chargeable offense.
The stalking analysis still applies. Because the course of conduct definition covers "two or more acts ... by any means," repeated AirTag surveillance combined with showing up at the victim's locations fits the pattern. From July 1, 2027, the amended stalking statutes also reach location tracking devices by name. Both Apple and Android phones now alert users to unknown trackers traveling with them, which is often how victims first discover the device.
Penalties
| Conduct | Statute | Classification | Maximum penalty |
|---|---|---|---|
| Placing a GPS tracker on another's car (single act) | None | Not a separate crime in Missouri | None under state law |
| Stalking, second degree | RSMo 565.227 | Class A misdemeanor | 1 year in jail, $2,000 fine |
| Stalking, second degree (repeat offense or officer victim) | RSMo 565.227 | Class E felony | 4 years in prison, $10,000 fine |
| Stalking, first degree | RSMo 565.225 | Class E felony | 4 years in prison, $10,000 fine |
| Stalking, first degree (officer victim or prior conviction) | RSMo 565.225 | Class D felony | 7 years in prison, $10,000 fine |
| Federal stalking (interstate or electronic surveillance) | 18 U.S.C. 2261A | Federal felony | 5 years in prison, more if the victim is injured |
These classifications are not changed by SS#2 for SB 999. What changes on July 1, 2027 is which conduct falls inside the stalking sections, as described above.
Jail and prison terms follow Missouri's general sentencing ranges in RSMo 558.011, and fines follow RSMo 558.002.
Civil Options and Orders of Protection
Criminal charges are not the only remedy. Missouri victims have two strong civil tracks.
Orders of protection. Chapter 455 lets victims of stalking petition for an ex parte order of protection without waiting for criminal charges. A full order can prohibit all contact, communication, and surveillance, and violating it is itself a crime. Our Missouri restraining order laws guide covers the process step by step.
One statute in this chapter causes constant confusion. RSMo 455.095, most recently amended by HB 495 effective August 28, 2025, lets courts order GPS monitoring with victim notification for people who violate orders of protection. The system tracks the offender and alerts the protected person and local police when the offender approaches. It is a tool that protects victims from offenders. It says nothing about whether private citizens can track each other, so do not rely on it for either permission or prohibition.
Invasion of privacy lawsuits. Missouri courts recognize the tort of intrusion upon seclusion, which the Missouri Supreme Court discussed in Sofka v. Thal (1983). Secretly monitoring someone's movements can support a claim for damages even when no criminal statute applies.
What to Do If You Find a Tracker on Your Car
- Photograph it in place before touching it. Location, wiring, and mounting all matter as evidence.
- Do not destroy it. The device, its serial number, and its account registration can identify who planted it.
- Think before removing it. If you suspect an abusive partner, removal tells them you know. Contact a domestic violence advocate to safety plan first.
- Report it to local police or the sheriff. Even without a tracking statute, the report documents one act in a potential stalking course of conduct.
- Keep a log of incidents where someone seemed to know your location.
- Consider an order of protection under chapter 455 if the tracking is part of following or harassment.
A mechanic or dealership can sweep the vehicle. Common hiding spots include the wheel wells, rear bumper cavity, under-seat area, and the OBD-II port under the dash.
Sources
- RSMo 565.225, Stalking, first degree (Missouri Revisor of Statutes)
- RSMo 565.227, Stalking, second degree, version in force through June 30, 2027 (Missouri Revisor of Statutes)
- RSMo 565.227, Stalking, second degree, version effective July 1, 2027 (Missouri Revisor of Statutes)
- SS#2 for SB 999 (2026), truly agreed to and finally passed text (Missouri Senate)
- Governor's action on SB 999, signed July 13, 2026 (Office of the Governor of Missouri)
- RSMo 565.002, Definitions, including course of conduct (Missouri Revisor of Statutes)
- RSMo 455.095, Electronic monitoring with victim notification (Missouri Revisor of Statutes)
- RSMo 575.205, Tampering with electronic monitoring equipment (Missouri Revisor of Statutes)
- 18 U.S.C. 2261A, Stalking (Cornell Law School, Legal Information Institute)
- United States v. Jones, 565 U.S. 400 (2012) (Supreme Court of the United States)
- Missouri HB 293 (2025), Unlawful tracking of a vehicle, bill summary (Missouri House of Representatives)
- Missouri HB 1911 (2026), Unlawful tracking of a motor vehicle, bill summary (Missouri House of Representatives)
For laws in other states, see our hub: GPS Tracking Laws by State.
This article is for informational purposes only and does not constitute legal advice. Laws change, and how they apply depends on your specific situation. Consult a licensed Missouri attorney for advice about your circumstances.
More Missouri Laws
Frequently Asked Questions
Is it illegal to put a GPS tracker on someone's car in Missouri?
Not as a single act. Missouri has no tracking device statute, so attaching a tracker to another person's car is not itself a crime. Through June 30, 2027, it becomes criminal stalking under RSMo 565.225 or 565.227 when it is part of a pattern of two or more acts that disturbs the victim. From July 1, 2027, the amended versions of those sections also reach technological abuse conduct, a defined term that names location tracking devices. Trespass and federal stalking charges can also apply.
Can I put a GPS tracker on my spouse's car in Missouri?
If the car is jointly titled, tracking it is generally lawful because you are an owner. If the car is titled only in your spouse's name, no Missouri statute forbids a single placement, but repeated covert monitoring can support a stalking charge, an order of protection, and an invasion of privacy lawsuit, and it rarely plays well in divorce court.
Did Missouri pass a GPS tracking law in 2025 or 2026?
Missouri did not create a standalone offense of unlawful tracking of a motor vehicle. HB 293 (2025) and HB 1911 (2026) would each have done that, and neither is in Missouri law. Missouri did enact SS#2 for SB 999 in 2026, signed by the governor on July 13, 2026, which repeals and re-enacts RSMo 565.002, 565.225 and 565.227 so the stalking statutes cover technological abuse conduct, including the use of location tracking devices. Those changes take effect July 1, 2027.
Can a private investigator legally use a GPS tracker in Missouri?
Missouri has no statute that either authorizes or prohibits PI tracking, so investigators operate in the same gap as everyone else. Careful investigators only place trackers on vehicles owned or co-owned by their client, because tracking a third party's car risks stalking allegations and civil liability.
Are AirTags treated differently than GPS trackers in Missouri?
No. Missouri law does not distinguish between Bluetooth item trackers and dedicated GPS units. The same stalking framework applies once tracking becomes a repeated course of conduct that disturbs the victim, and from July 1, 2027 the amended stalking statutes reach location tracking devices by name.
What is Missouri's RSMo 455.095 electronic monitoring law?
It lets courts order GPS monitoring with victim notification for people who violate orders of protection, tracking the offender and alerting the victim and police when the offender comes near. It regulates court-ordered offender monitoring only and has nothing to do with private citizens tracking each other.
Can police put a GPS tracker on my car without a warrant in Missouri?
Generally no. In United States v. Jones (2012), the U.S. Supreme Court held that attaching a GPS device to a vehicle and using it to monitor movements is a Fourth Amendment search, so police normally need a warrant.
Updates
Corrected the claim that no tracking-related bill passed: Missouri enacted SS#2 for SB 999 in 2026, which rewrites the stalking statutes to cover location tracking devices effective July 1, 2027, and the stalking section now separates the law in force today from the version that takes over on that date.
Governing law re-checked for recent changes
Governing law re-checked for recent changes
Independently fact-checked against the cited primary sources
The Law Behind This Article
This article rests on the statutory provisions below, held in our own legal record and retrieved from the official source. Tap a section to read the operative text.
Revised Statutes of Missouri, Title XXXVIII (CRIMES AND PUNISHMENT; PEACE OFFICERS AND PUBLIC DEFENDERS), Chapter 565
§ 565.227Stalking, second degree, penalty.In force
1. A person commits the offense of stalking in the second degree if he or she purposely, through his or her course of conduct, disturbs, or follows with the intent to disturb another person. 2. This section shall not apply to activities of federal, state, county, or municipal law enforcement officers conducting investigations of any violation of federal, state, county, or municipal law. 3. Any law enforcement officer may arrest, without a warrant, any person he or she has probable cause to believe has violated the provisions of this section.
Official text (excerpt) · last checked 2026-08-26 · Read the full text in our law library · Verify at revisor.mo.gov
§ 565.225Stalking, first degree, penalty.In forcecited in 2 of our articles
1. As used in this section and section 565.227, the term "disturbs" shall mean to engage in a course of conduct directed at a specific person that serves no legitimate purpose and that would cause a reasonable person under the circumstances to be frightened, intimidated, or emotionally distressed. 2. A person commits the offense of stalking in the first degree if he or she purposely, through his or her course of conduct, disturbs or follows with the intent of disturbing another person and: (1) Makes a threat communicated with the intent to cause the person who is the target of the threat to reasonably fear for his or her safety, the safety of his or her family or household member, or the safety of domestic animals or livestock as defined in section 276.606 kept at such person's residence or on such person's property. The threat shall be against the life of, or a threat to cause physical injury to, or the kidnapping of the person, the person's family or household members, or the person's domestic animals or livestock as defined in section 276.606 kept at such person's residence or on such person's property; or (2) At least one of the acts constituting the course of conduct…
Official text (excerpt) · last checked 2026-07-31 · Read the full text in our law library · Verify at revisor.mo.gov
Cited in 17 court opinions in our collectionLatest citing opinion in our collection: 2023
Opinions citing this section in our collection:
- State v. Mabry (Missouri Court of Appeals 2009, 285 S.W.3d 780)“…tive because it included the definition of “stalking” under Mo.Rev.Stat. § 565.225.2 instead of the definition provided by…”
- State v. Vaughn (Supreme Court of Missouri 2012, 366 S.W.3d 513)“…with both "frighten” and "intimidate.” See section 565.225, RSMo Supp.2008.…”
- State v. Dawson (Missouri Court of Appeals 1999, 985 S.W.2d 941)“…rial, William Dawson was convicted of stalking, pursuant to § 565.225, RSMo 1994, 1 and third degree a…”
Identified automatically from the court opinions citing this section — not a ranking of which case controls.
Also relied on in: Missouri Employee Monitoring Laws: Workplace Surveillance and Privacy (2026)
§ 565.002Definitions.In force
As used in this chapter, unless a different meaning is otherwise plainly required the following terms mean: (1) "Adequate cause", cause that would reasonably produce a degree of passion in a person of ordinary temperament sufficient to substantially impair an ordinary person's capacity for self-control; (2) "Child", a person under seventeen years of age; (3) "Conduct", includes any act or omission; (4) "Course of conduct", a pattern of conduct composed of two or more acts, which may include communication by any means, over a period of time, however short, evidencing a continuity of purpose. Constitutionally protected activity is not included within the meaning of course of conduct. Such constitutionally protected activity includes picketing or other organized protests; (5) "Deliberation", cool reflection for any length of time no matter how brief; (6) "Domestic victim", a household or family member as the term "family" or "household member" is defined in section 455.010, including any child who is a member of the household or family; (7) "Emotional distress", something markedly greater than the level of uneasiness, nervousness, unhappiness, or the like which are…
Official text (excerpt) · last checked 2026-07-31 · Read the full text in our law library · Verify at revisor.mo.gov
Cited in 24 court opinions in our collectionLatest citing opinion in our collection: 2025
Opinions citing this section in our collection:
- State v. Roper (Missouri Court of Appeals 2004, 136 S.W.3d 891)“…Serious physical injury,” in turn, is defined in Section 565.002, RSMo, as “physical injury that creates a sub…”
- Strong v. State (Supreme Court of Missouri 2008, 263 S.W.3d 636)“…deliberation is premised on the mental state of Mr. Strong. Section 565.002, RSMo 2000 (defining deliberation as a cool r…”
- State v. Roe (Missouri Court of Appeals 1992, 845 S.W.2d 601)“…d 342, 343 (Mo.1982). “Deliberation” is defined in RSMo § 565.002(3) (1986) as “cool reflection for any l…”
Identified automatically from the court opinions citing this section — not a ranking of which case controls.
Revised Statutes of Missouri, Title XXX (DOMESTIC RELATIONS), Chapter 455
§ 455.095Electronic monitoring, when — requirements.In force
1. For purposes of this section, the following terms mean: (1) "Electronic monitoring with victim notification", an electronic monitoring system that has the capability to track and monitor the movement of a person and immediately transmit the monitored person's location to the protected person and the local law enforcement agency with jurisdiction over the protected premises through an appropriate means, including the telephone, an electronic beeper, or paging device whenever the monitored person enters the protected premises as specified in the order by the court; (2) "Informed consent", the protected person is given the following information before consenting to participate in electronic monitoring with victim notification: (a) The protected person's right to refuse to participate in such monitoring and the process for requesting the court to terminate his or her participation after it has been ordered; (b) The manner in which the electronic monitoring technology functions and the risks and limitations of that technology; (c) The boundaries imposed on the person being monitored during the electronic monitoring; (d) The sanctions that the court may impose for…
Official text (excerpt) · last checked 2026-07-31 · Read the full text in our law library · Verify at revisor.mo.gov
Revised Statutes of Missouri, Title XXXVIII (CRIMES AND PUNISHMENT; PEACE OFFICERS AND PUBLIC DEFENDERS), Chapter 575
§ 575.205Tampering with electronic monitoring equipment, offense of — violation, penalty.In force
1. A person commits the offense of tampering with electronic monitoring equipment if he or she intentionally removes, alters, tampers with, damages, or destroys electronic monitoring equipment which a court, the division of probation and parole or the parole board has required such person to wear. 2. This section does not apply to the owner of the equipment or an agent of the owner who is performing ordinary maintenance or repairs on the equipment. 3. The offense of tampering with electronic monitoring equipment is a class D felony.
Official text (excerpt) · last checked 2026-07-31 · Read the full text in our law library · Verify at revisor.mo.gov
Revised Statutes of Missouri, Title XXXVIII (CRIMES AND PUNISHMENT; PEACE OFFICERS AND PUBLIC DEFENDERS), Chapter 558
§ 558.011Sentence of imprisonment, terms — conditional release.In forcecited in 11 of our articles
1. The authorized terms of imprisonment, including both prison and conditional release terms, are: (1) For a class A felony, a term of years not less than ten years and not to exceed thirty years, or life imprisonment; (2) For a class B felony, a term of years not less than five years and not to exceed fifteen years; (3) For a class C felony, a term of years not less than three years and not to exceed ten years; (4) For a class D felony, a term of years not to exceed seven years; (5) For a class E felony, a term of years not to exceed four years; (6) For a class A misdemeanor, a term not to exceed one year; (7) For a class B misdemeanor, a term not to exceed six months; (8) For a class C misdemeanor, a term not to exceed fifteen days.
Official text (excerpt) · last checked 2026-07-31 · Read the full text in our law library · Verify at revisor.mo.gov
Cited in 128 court opinions in our collectionLatest citing opinion in our collection: 2025
Opinions citing this section in our collection:
- Rentschler v. Nixon (Supreme Court of Missouri 2010, 311 S.W.3d 783)“…When all were sentenced, the conditional release statute, section 558.011, RSMo 1978, was silent regarding whether viol…”
- Hall v. Missouri Bd. of Probation and Parole (Missouri Court of Appeals 1999, 10 S.W.3d 540)“…court erroneously declared and applied the law by applying § 558.011, RSMo 1994, as opposed to the 1986 version, t…”
- State v. Quisenberry (Supreme Court of Missouri 1982, 639 S.W.2d 579)“…If not, court imposition of a longer sentence is error. Section 558.011, RSMo Cum.Supp.1981, provides in pertinent pa…”
Identified automatically from the court opinions citing this section — not a ranking of which case controls.
Also relied on in: Missouri Dog Bite Laws: Liability and Victim Rights, Missouri Recording Laws (2026): One-Party Consent Rules, Missouri Audio Recording Laws: One-Party Consent Rules and Penalties
§ 558.002Fines for felonies.In forcecited in 6 of our articles
1. Except as otherwise provided for an offense outside this code, a person who has been convicted of an offense may be sentenced to pay a fine which does not exceed: (1) For a class C, D, or E felony, ten thousand dollars; (2) For a class A misdemeanor, two thousand dollars; (3) For a class B misdemeanor, one thousand dollars; (4) For a class C misdemeanor, seven hundred fifty dollars; (5) For a class D misdemeanor, five hundred dollars; (6) For an infraction, four hundred dollars; or (7) If the person has gained money or property through the commission of the offense, to pay an amount, fixed by the court, not exceeding double the amount of the person's gain from the commission of the offense.
Official text (excerpt) · last checked 2026-07-31 · Read the full text in our law library · Verify at revisor.mo.gov
Cited in 5 court opinions in our collectionLatest citing opinion in our collection: 2024
Opinions citing this section in our collection:
- STATE OF MISSOURI v. WARREN DALE BRANNING, Defendant-Respondent (Missouri Court of Appeals 2024)“…unishable upon conviction under Sections 558.011 and 558.002, RSMo, in that on or about August 18, 2021, i…”
- State of Missouri v. Ashley Colville (Supreme Court of Missouri 2024)“…punishable upon conviction under Sections 558.011 and 558.002, RSMo, in that on or about September 2…”
- State of Missouri v. Andrew P. Minnick (Missouri Court of Appeals 2023)“…viction under Sections 562.012, 566.100, 558.011, and 558.002, RSMo, in that on or about October 18,…”
Identified automatically from the court opinions citing this section — not a ranking of which case controls.
Also relied on in: Missouri Ring Doorbell Laws: What You Need to Know in 2026, Missouri AI Meeting Recording Laws (2026), Missouri Surveillance Camera Laws (2026 Guide)
United States Code Title 18
§ 2261AStalkingIn forcecited in 53 of our articles
Whoever— travels in interstate or foreign commerce or is present within the special maritime and territorial jurisdiction of the United States, or enters or leaves Indian country, with the intent to kill, injure, harass, intimidate, or place under surveillance with intent to kill, injure, harass, or intimidate another person, and in the course of, or as a result of, such travel or presence engages in conduct that— places that person in reasonable fear of the death of, or serious bodily injury to— that person; an immediate family member (as defined in section 115) of that person; a spouse or intimate partner of that person; or the pet, service animal, emotional support animal, or horse of that person; or causes, attempts to cause, or would be reasonably expected to cause substantial emotional distress to a person described in clause (i), (ii), or (iii) of subparagraph (A); or with the intent to kill, injure, harass, intimidate, or place under surveillance with intent to kill, injure, harass, or intimidate another person, uses the mail, any interactive computer service or electronic communication service or electronic communication system of interstate commerce, or any other…
Official text (excerpt) · last checked 2026-07-28 · Read the full text in our law library · Verify at uscode.house.gov
Cited in 350 court opinions in our collectionLatest citing opinion in our collection: 2026
In the courts (editorial summary, independently checked):Federal appeals courts have construed and upheld Section 2261A. United States v. Walker (2011) read in the course of, or as a result of such travel disjunctively, so pre-travel threats plus resulting fear sufficed. United States v. Amy Gonzalez (2018) held it neither overbroad nor vague and no First Amendment violation as applied.
Opinions citing this section in our collection:
- United States v. Walker (Court of Appeals for the First Circuit 2011, 665 F.3d 212)✓After emailing threats to his estranged wife, the defendant flew from Michigan to Puerto Rico and was arrested on arrival. The court read the disjunctive phrase in 2261A(1) to cover travel that itself places the target in reasonable fear, and upheld the stalking conviction.
- United States v. Amy Gonzalez (Court of Appeals for the Third Circuit 2018, 905 F.3d 165)✓Relatives waged a years-long campaign against a mother that ended in a courthouse shooting. The court held 2261A is neither overbroad nor vague because it reaches harassing conduct, and that the mental states it lists are alternative means, not elements; convictions affirmed.
- United States v. Wills (Court of Appeals for the Fourth Circuit 2003, 346 F.3d 476)✓A burglary suspect pursued the witness who identified him at a preliminary hearing; the witness later died. The court held the evidence met each element of 2261A: travel from D.C. to Virginia, intent to harm or harass, and reasonable fear of death; conviction affirmed.
Identified automatically from the court opinions citing this section — not a ranking of which case controls.
Also relied on in: Alabama GPS Tracking Laws: Is It Legal to Put a Tracker on a Car? (2026), Colorado GPS Tracking Laws: Is It Legal to Put a Tracker on a Car? (2026), Florida GPS Tracking Laws: Is It Legal to Put a Tracker on a Car? (2026)
Search our full record of US law — 2.1 million sections, every state + federal →
Sources and References
- RSMo 565.225, Stalking, first degree(revisor.mo.gov)
- RSMo 565.227, Stalking, second degree(revisor.mo.gov)
- RSMo 565.002, Definitions (course of conduct)(revisor.mo.gov)
- RSMo 455.095, Electronic monitoring with victim notification(revisor.mo.gov)
- 18 U.S.C. 2261A, Stalking(law.cornell.edu)
- United States v. Jones, 565 U.S. 400 (2012)(supremecourt.gov)
- Missouri HB 293 (2025) bill summary(documents.house.mo.gov)
- SS#2 for SB 999 (2026), truly agreed to and finally passed text(senate.mo.gov)
- Governor's action on SB 999, signed July 13, 2026(governor.mo.gov)
- RSMo 565.227, Stalking, second degree, version in force through June 30, 2027(revisor.mo.gov)
- Missouri HB 1911 (2026), Unlawful tracking of a motor vehicle, bill summary(documents.house.mo.gov)