Stalking is a term commonly used to refer to unwanted and obsessive attention by an individual or group to another person. Stalking behaviors are related to harassment and intimidation and may include following the victim in person and/or monitoring them via the internet. The word stalking is used, with some differing meanings, in psychology and psychiatry and also in some legal jurisdictions as a term for a criminal offense.

According to a 2002 report by the National Center for Victims of Crime, "Virtually any unwanted contact between two people that directly or indirectly communicates a threat or places the victim in fear can be considered stalking."[1]



The difficulties associated with precisely defining this term (or defining it at all) are well documented.[2]

Having been used since at least the 16th century to refer to a prowler or a poacher (Oxford English Dictionary), the term stalker started to be used by the media in the 20th century to describe people who pester and harass others, initially with specific reference to the harassment of celebrities by strangers who were described as being "obsessed".[3] This use of the word appears to have been coined by the tabloid press in the United States.[4]

Pathé and Mullen describe stalking as "a constellation of behaviours in which an individual inflicts upon another repeated unwanted intrusions and communications".[5]

Stalking can be defined as the willful and repeated following, watching and/or harassing of another person. Most of the time, the purpose of stalking is to attempt to force a relationship with someone who is unwilling or otherwise unavailable. Unlike other crimes, which usually involve one act, stalking is a series of actions that occur over a period of time. Although stalking is illegal, some of the actions that can contribute to stalking are initially legal, such as gathering information, calling someone on the phone, sending gifts, emailing or instant messaging. They become illegal when they breach the legal definition of harassment e.g. an action such as sending a text is not usually illegal, but is illegal when frequently repeated to an unwilling recipient. In fact United Kingdom law states the incident only has to happen twice when the stalker should be aware their behavior is unacceptable e.g. two phone calls to a stranger, two gifts following the victim then phoning them etc. However, the victim may feel they have been the victim of a stalking after one incident e.g. being followed home.[6]

Psychology and behaviors

People characterized as stalkers may have a mistaken belief that another person loves them (erotomania), or that they need rescuing.[6] Stalking can sometimes consist of an accumulation of a series of actions which in themselves can be legal, such as calling on the phone, sending gifts, or sending emails.[7] In the United Kingdom, government research demonstrates that, despite media reports and research of vested interests, the Protection from Harassment Act 1997 "is rarely used for stalking as portrayed by the media since only a small minority of cases in the survey involved such behaviour".[8]

Stalkers may use threats and violence to frighten their victims. They may also engage in vandalism and property damage or make physical attacks that are mostly meant to frighten. Less common are sexual assaults.[6]

In the UK, for example, most stalkers are former partners and evidence indicates that the mentally ill stalking type of behaviour propagated in the media occurs in only a minority of cases of alleged stalking.[8] A UK Home Office Research study on the use the 1997 Protection from Harassment Act quotes "The study found that the Protection from Harassment Act is being used to deal with a variety of behaviour such as domestic and inter-neighbour disputes. It is rarely used for stalking as portrayed by the media since only a small minority of cases in the survey involved such behaviour.[8]

Psychological effects on victims

Disruptions in daily life necessary to escape the stalker, including changes in employment, residence and phone numbers, may take a toll on the victim's well-being and lead to a sense of isolation.[9]

According to Lamber Royakkers, "Stalking is a form of mental assault, in which the perpetrator repeatedly, unwantedly, and disruptively breaks into the life-world of the victim, with whom they have no relationship (or no longer have). Moreover, the separated acts that make up the intrusion cannot by themselves cause the mental abuse, but do taken together (cumulative effect)."[7]

Gender studies of stalkers

According to one study, women often target other women, whereas men generally stalk women only.[10][11] However, a January 2009 report from the Department of Justice in the United States reports that "Males were as likely to report being stalked by a male as a female offender. 43% of male stalking victims stated that the offender was female, while 41% of male victims stated that the offender was another male. Female victims of stalking were significantly more likely to be stalked by a male (67%) rather than a female (24%) offender." This report provides considerable data by gender and race about both stalking and harassment.[12] The data for this report were obtained via the 2006 Supplemental Victimization Survey (SVS), conducted by the U.S. Census Bureau for the U.S. Department of Justice.[13]

Types of stalkers

Psychologists often group individuals who stalk into two categories: psychotic and nonpsychotic.[14] Stalkers may have pre-existing psychotic disorders such as delusional disorder, schizoaffective disorder, or schizophrenia. Most stalkers are nonpsychotic and may exhibit disorders or neuroses such as major depression, adjustment disorder, or substance dependence, as well as a variety of Axis II personality disorders (such as antisocial, avoidant, borderline, dependent, narcissistic, or paranoid). Some of the symptoms of "obsessing" over a person is part of obsessive compulsive personality disorder. The nonpsychotic stalkers' pursuit of victims can be influenced by various psychological factors, including anger, hostility, projection of blame, obsession, dependency, minimization, denial, and jealousy. Conversely, as is more commonly the case, the stalker has no antipathic feelings towards the victim, but simply a longing that cannot be fulfilled due to deficiencies either in their personality or their society's norms.[15]

In "A Study of Stalkers" Mullen et al.. (2000)[16] identified five types of stalkers:

  • Rejected stalkers pursue their victims in order to reverse, correct, or avenge a rejection (e.g. divorce, separation, termination).
  • Resentful stalkers pursue a vendetta because of a sense of grievance against the victims – motivated mainly by the desire to frighten and distress the victim.
  • Intimacy seekers seek to establish an intimate, loving relationship with their victim. To many of them the victim is a long-sought-after soul mate, and they were 'meant' to be together.
  • Incompetent suitors, despite poor social or courting skills, have a fixation, or in some cases, a sense of entitlement to an intimate relationship with those who have attracted their amorous interest. Their victims are most often already in a dating relationship with someone else.
  • Predatory stalkers spy on the victim in order to prepare and plan an attack – often sexual – on the victim.

The 2002 National Victim Association Academy defines an additional form of stalking: The vengeance/terrorist stalker. Both the vengeance stalker and terrorist stalker (the latter sometimes called the political stalker) do not, in contrast with some of the aforementioned types of stalkers, seek a personal relationship with their victims but rather force them to emit a certain response favourable to the stalker. While the vengeance stalker's motive is "to get even" with the other person whom he/she perceives has done some wrong to them (e.g., an employee who believes is fired without justification from their job by their superior), the political stalker intends to accomplish a political agenda, also using threats and intimidation to force his/her target to refrain and/or become involved in some particular activity, regardless of the victim’s consent.[17]

Many stalkers[quantify] fit categories with paranoia disorders. Intimacy-seeking stalkers often have delusional disorders involving erotomanic delusions. With rejected stalkers, the continual clinging to a relationship of an inadequate or dependent person couples with the entitlement of the narcissistic personality, and the persistent jealousy of the paranoid personality. In contrast, resentful stalkers demonstrate an almost “pure culture of persecution,” with delusional disorders of the paranoid type, paranoid personalities, and paranoid schizophrenia.[16]

One of the uncertainties in understanding the origins of stalking is that the concept is now widely understood in terms of specific behaviors[18] which are found to be offensive and/or illegal. As discussed above, these specific (apparently stalking) behaviors may have multiple motivations.

In addition, the personality characteristics that are often discussed as antecedent to stalking may also produce behavior that is not stalking as conventionally defined. Some research suggests there is a spectrum of what might be called "obsessed following behavior." People who complain obsessively and for years, about a perceived wrong or wrong-doer, when no one else can perceive the injury—and people who cannot or will not "let go" of a person or a place or an idea—comprise a wider group of persons that may be problematic in ways that seem similar to stalking. Some of these people get extruded from their organizations—they may get hospitalized or fired or let go if their behavior is defined in terms of illegal stalking, but many others do good or even excellent work in their organizations and appear to have just one focus of tenacious obsession.[19]


Cyberstalking is the use of computers or other electronic technology to facilitate stalking. A booming “spy shop” industry has sprouted up to supply Hi-tech equipment such as computer hacking or monitoring software, hidden cameras, microphones, and GPS tracking units.[20]

Stalking by groups

According to a U.S. Department of Justice special report[12] a significant number of people reporting stalking incidents claim that they had been stalked by more than one person, with 18.2% reporting that they were stalked by two people, 13.1% reporting that they had been stalked by three or more. The report did not break down these cases into numbers of victims who claimed to have been stalked by several people individually, and by people acting in concert. Official Department of Justice documents, obtained through the Freedom of Information Act, reveal that, of the 13% of victim reports of 3 or more stalkers "acting in concert", 41% of subjects in these cases reported that they were the target of teams or groups of stalkers working together.[21] The data for this report were obtained via the 2006 Supplemental Victimization Survey (SVS), conducted by the U.S. Census Bureau for the U.S. Department of Justice.[13]

According to a United Kingdom study by Sheridan and Boon,[22] in 5% of the cases they studied there was more than one stalker, and 40% of the victims said that friends or family of their stalker had also been involved. In 15% of cases, the victim was unaware of any reason for the harassment.

Stalking by groups is also known as Gang stalking. [23][24]

False claims of stalking and delusions of persecution

In 1999, Pathe, Mullen and Purcell wrote that popular interest in stalking was promoting false claims.[25] In 2004, Sheridan and Blaauw said that they estimated that 11.5% of claims in a sample of 357 reported claims of stalking were false.[26]

According to Sheridan and Blaauw, 70% of false stalking reports were made by people suffering from delusions of persecution.[26][27] Another study estimated the proportion of false reports that were due to delusions as 64%.[28]

Multiple news reports have described how groups of Internet users have cooperated to exchange detailed conspiracy theories involving coordinated activities by large numbers of people and the use of "psychotronic weapons" and other alleged mind control techniques. These are generally reported by external observers as being examples of belief systems, as opposed to reports of objective phenomena.[29][30]

Epidemiology and prevalence


According to a study conducted by Purcell, Pathé and Mullen (2002), 23% of the Australian population reported having been stalked.[31]


Stieger, Burger and Schild conducted a survey in Austria, revealing a lifetime prevalence of 11% (women: 17%, men: 3%).[32][33] Further results include: 86% of stalking victims were female, 81% of the stalkers were male. Women were mainly stalked by men (88%) while men were almost equally stalked by men and women (60% male stalkers). 19% of the stalking victims reported that they were still being stalked at the time of study participation (point prevalence rate: 2%). To 70% of the victims, the stalker was known, being a prior intimate partner in 40%, a friend or acquaintance in 23% and a colleague at work in 13% of cases. As a consequence, 72% of the victims reported having changed their lifestyle. 52% of former and ongoing stalking victims reported suffering from a currently impaired (pathological) psychological well-being. There was no significant difference between the incidence of stalking in rural and urban areas.

England and Wales

Budd and Mattinson found a lifetime prevalence of 12% in England and Wales (16% female, 7% males).[34]

According to a paper by staff from the Fixated Threat Assessment Centre, a unit established to deal with people with fixations on public figures, 86% of a sample group of 100 people assessed by them appeared to them to suffer from psychotic illness; 57% of the sample group were subsequently admitted to hospital, and 26% treated in the community.[35]

A similar retrospective study published in 2009 in Psychological Medicine based on a sample of threats to the Royal Family kept by the Metropolitan Police Service over a period of 15 years, suggested that 83.6% of the writers of these letters suffered from serious mental illness.[36]


Dressing, Kuehner and Gass conducted a representative survey in Mannheim, a middle-sized German city, and reported a lifetime prevalence of having been stalked of about 12%.[37]

United States

Tjaden and Thoennes reported a lifetime prevalence (being stalked) of 8% in women and 2% in males (depending on how strict the definition) in the National violence against women survey.[38]

Laws on harassment and stalking


Every Australian state enacted laws prohibiting stalking during the 1990s, with Queensland was the first state to do so in 1994. The laws vary slightly from state to state, with Queensland's laws having the broadest scope, and South Australian laws the most restrictive. Punishments vary from a maximum of 10 years imprisonment in some states, to a fine for the lowest severity of stalking in others. Australian anti-stalking laws have some notable features. Unlike many US jurisdictions they do not require the victim to have felt fear or distress as a result of the behaviour, only that a reasonable person would have felt this way. In some states, the anti-stalking laws operate extra-territorially, meaning that an individual can be charged with stalking if either they or the victim are in the relevant state. Most Australian states provide the option of a restraining order in cases of stalking, breach of which is punishable as a criminal offence. There has been relatively little research into Australian court outcomes in stalking cases, although Freckelton (2001) found that in the state of Victoria, most stalkers received fines or community based dispositions.


Section 264 of the Criminal Code of Canada, titled "criminal harassment"[39] addresses acts which are termed "stalking" in many other jurisdictions. The provisions of the section came into force in August 1993 with the intent of further strengthening laws protecting women.[40] It is a hybrid offence, which may be punishable upon summary conviction or as an indictable offence, the latter of which may carry a prison term of up to ten years. Section 264 has withstood Charter challenges.[41]

The Chief, Policing Services Program, for Statistics Canada has stated:

"... of the 10,756 incidents of criminal harassment reported to police in 2006, 1,429 of these involved more than one accused."


In 2000, Japan enacted a national law to combat this behaviour, after the murder of Shiori Ino.[42] Acts of stalking can be viewed as "interfering [with] the tranquility of others' lives" and are prohibited under petty offence laws.


Following a series of high-profile incidents that came to public attention in the past years, a law was proposed in June 2008, and became effective in February 2009, making a criminal offence, punishable with imprisonment ranging from six months up to four years, any "continuative harassing, threatening or persecuting behaviour which: (1) causes a state of anxiety and fear in the victim(s), or; (2) ingenerates within the victim(s) a motivated fear for his/her own safety or for the safety of relatives, kins [sic], or others tied to the victim him/herself by an affective relationship, or; (3), forces the victim(s) to change his/her living habits". If the perpetrator of the offense is a subject tied to the victim by kinship or that is or has been in the past involved in a relationship with the victim (i.e. current or former/divorced/split husband/wife or fiancée), and/or if the victim is a pregnant woman or a minor, the sanction can be elevated up to six years of incarceration.[43][44]</ref>[5][dead link]</ref>

United Kingdom

There is no offence which is described in law as "stalking". An attempt to create such an offence by the Stalking Bill 1996 failed. It was felt that the proposed offence failed to distinguish between reasonable and unreasonable conduct.

In England and Wales, "harassment" was criminalised by the enactment of the Protection from Harassment Act 1997, which came into force on June 16, 1997. It makes it a criminal offence, punishable by up to six months imprisonment, to pursue a course of conduct which amounts to harassment of another on two or more occasions. The court can also issue a restraining order, which carries a maximum punishment of five years imprisonment if breached. In England and Wales, liability may arise in the event that the victim suffers either mental or physical harm as a result of being harassed (or slang term stalked) (see R. v. Constanza).

Already before the enactment of the Act, the Malicious Communications Act 1988 and the Telecommunications Act 1984 (now the Communications Act 2003) criminalised indecent, offensive or threatening phone calls and the sending of an indecent, offensive or threatening letter, electronic communication or other article to another person.

Obtaining evidence of stalking is a simple[neutrality is disputed] procedure using the Regulation of Investigatory Powers Act which enables the authorities to quickly obtain records of communication.[citation needed]

In Scotland, provision is made under the Protection from Harassment Act against stalking. It is not a criminal offence, however, but falls under the law of delict. Victims of stalking may sue for interdict against an alleged stalker, or a non-harassment order, breach of which is an offence.[citation needed]

United States

The first state to criminalize stalking in the United States was California in 1990[45] due to several high profile stalking cases in California, including the 1982 attempted murder of actress Theresa Saldana,[46] the 1988 massacre by Richard Farley,[47] the 1989 murder of actress Rebecca Schaeffer,[48] and five Orange County stalking murders also in 1989.[47][49] The first anti-stalking law in the United States, California Penal Code Section 646.9, was developed and proposed by Municipal Court Judge John Watson of Orange County. Watson with U.S. Congressman Ed Royce introduced the law in 1990.[49][50] Also in 1990, the Los Angeles Police Department (LAPD) began the United States' first Threat Management Unit, founded by LAPD Captain Robert Martin.

Within three years[49] thereafter, every state in the United States followed suit to create the crime of stalking, under different names such as criminal harassment or criminal menace. The Driver's Privacy Protection Act (DPPA) was enacted in 1994 in response to numerous cases of a driver's information being abused for criminal activity, examples such as the Saldana and Schaeffer stalking cases.[51][52] The DPPA prohibits states from disclosing a driver's personal information without consent by State Department of Motor Vehicles (DMV). As of 2011, stalking is an offense under section 120a of the Uniform Code of Military Justice (UCMJ).[53] The law took effect on 1 October 2007.[54]

See also


  1. ^ National Center for Victims of Crime (February 2002). "Stalking Victimization". Office for Victims of Crime. 
  2. ^ Sheridan, L. P.; Blaauw, E. (2004). "Characteristics of False Stalking Reports". Criminal Justice and Behavior 31: 55–72. doi:10.1177/0093854803259235. "Given that stalking may often constitute no more than the targeted repetition of ostensibly ordinary or routine behavior, stalking is inherently difficult to define." 
  3. ^ P. E. Mullen et al. Stalkers and Their Victims, 2nd edition. Cambridge University Press, 2007.
  4. ^ Lawson-Cruttenden, 1996, Is there a law against stalking?, New Law Journal/6736 pp.418-420, cited here [1]
  5. ^ Pathe, M.; Mullen, P. E. (1997). "The impact of stalkers on their victims". The British Journal of Psychiatry 170: 12–17. doi:10.1192/bjp.170.1.12. PMID 9068768.  edit
  6. ^ a b c "Stalking". Retrieved 2010-10-20. 
  7. ^ a b "CyberStalking: menaced on the Internet". 
  8. ^ a b c Jessica Harris (2000). "The Protection from Harassment Act 1997 – An Evaluation of its Use and Effectiveness". Home Office Research, Development and Statistics Directorate. ISSN 1364-6540. Retrieved 2010-10-20. 
  9. ^ Abrams KM and Robinson GE (September 1, 2008). "Comprehensive Treatment of Stalking Victims: Practical Steps That Help Ensure Safety". Psychiatric Times 25 (10). 
  10. ^ Rosemary Purcell, Michele Pathé, and Paul E. Mullen. A Study of Women Who Stalk. AJP 2001 Am J Psychiatry 158:2056-2060, December 2001
  11. ^ "Types of stalkers". Retrieved 2010-10-20. 
  12. ^ a b "Stalking Victimization in the United States", United States Department of Justice
  13. ^ a b "SUPPLEMENTAL VICTIMIZATION SURVEY (SVS)". United States Department of Justice. 
  14. ^ Mullen et al.. Stalkers and Their Victims. Cambridge University Press, 2000.
  15. ^ KK Kienlen, DL Birmingham, KB Solberg, JT O'Regan, and Meloy JR. A comparative study of psychotic and nonpsychotic stalking J Am Acad Psychiatry Law 25:3:317-334 (1997)
  16. ^ a b Paul E. Mullen, Michele Pathé, Rosemary Purcell, and Geoffrey W. Stuart.A Study of Stalkers Am J Psychiatry 156:1244-1249, August 1999
  17. ^ 2002 National Victim Assistance Academy "National Victim Assistance Academy Textbook - Chapter 22 Special Topics - Section 4, Campus Crime and Victimization". Office for Victims of Crime. June 2002. 2002 National Victim Assistance Academy. Retrieved 2011-08-28. 
  18. ^ as a US example, see January 2009 Special Report from the Department of Justice in the US titled "Stalking Victimization in the United States", NCJ 224527
  19. ^ (See Mary Rowe, "People With Delusions or Quasi-Delusions Who ‘Won't Let Go’," Journal of the University and College Ombuds Association, Occasional Paper, Number 1, Fall 1994.)
  20. ^ Leah Yamshon (Feb 12, 2010). "GPS: A Stalker's Best Friend". PCWorld. 
  21. ^ Office of Justice Programs, F.O.I.A. No. 10-000169, Source: Office of the General Counsel, Office of Justice Programs, U.S. Department of Justice: DOJ F.O.I.A. Document 1 , DOJ F.O.I.A. Document 2 , DOJ F.O.I.A. Document 3
  22. ^ Article: "The Course and Nature of Stalking: A Victim Perspective", Authors: Sheridan, Davies, Boon. Source: Howard Journal of Criminal Justice, Volume 40, Number 3, August 2001 , pp. 215-234.
  23. ^ Candice Nguyen, Central Coast News (January 29, 2011). "Gang Stalking, “Bullying on Steroids”". Central Coast News, KION 46, FOX 35, California. Retrieved 2011-10-13. 
  24. ^ Joe Conger (February 17, 2010). "Stalked, drugged and raped: Is it happening in San Antonio?". KENS 5, San Antonio, TX. Retrieved 2011-10-13. 
  25. ^ M Pathe, PE Mullen, R Purcell; Stalking: false claims of victimisation; British Journal of Psychiatry 174: 170-172 (1999)[2]
  26. ^ a b L. P. Sheridan, E. Blaauw; Characteristics of False Stalking Reports; Criminal Justice and Behavior, Vol. 31, No. 1, 55-72 (2004) doi:10.1177/0093854803259235 [3]
  27. ^ "After eight uncertain cases were excluded, the false reporting rate was judged to be 11.5%, with the majority of false victims suffering delusions (70%)." [4]
  28. ^ Brown, S. A. (2008). "The Reality of Persecutory Beliefs: Base Rate Information for Clinicians". Ethical Human Psychology and Psychiatry 10 (3): 163–178. doi:10.1891/1559-4343.10.3.163. "Collapsing across two studies that examined 40 British and 18 Australian false reporters (as determined by evidence overwhelmingly against their claims), these individuals fell into the following categories: delusional (64%), factitious/attention seeking (15%), hypersensitivity due to previous stalking (12%), were the stalker themselves (7%), and malingering individuals (2%) (Purcell, Pathe, & Mullen, 2002; Sheridan & Blaauw, 2004)."  edit
  29. ^ Sharon Weinberger (January 14, 2007). "Mind Games". Washington Post. Retrieved 2010-08-01. 
  30. ^ Sarah Kershaw (November 12, 2008). "Sharing Their Demons on the Web". New York Times. Retrieved 2010-08-01. 
  31. ^ Rosemary Purcell (2006). "The prevalence and nature of stalking in the Australian community". 
  32. ^ Burger, Christoph; Anne Schild, Stefan Stieger (2008-08-27). "Lifetime prevalence and impact of stalking: Epidemiological data from Eastern Austria" (in Englisch). ICP2008. Retrieved 2008-01-17. 
  33. ^ Stieger, Stefan; Burger Christoph, Anne Schild (2008-10-14). "Lifetime prevalence and impact of stalking: Epidemiological data from Eastern Austria". Eur. J. Psychiat. Vol. 22, N.° 4, (235-241). Retrieved 2008-02-24. 
  34. ^ Budd, Tracey; Joanna Mattinson,Andy Myhill (2000). "The extend and nature of stalking: findings from the 1998 British crime survey". British Crime Survey. Retrieved 2006-12-12. 
  35. ^ James, D.; Kerrigan, T.; Forfar, R.; Farnham, F.; Preston, L. (2010). "The Fixated Threat Assessment Centre: preventing harm and facilitating care". Journal of Forensic Psychiatry & Psychology 21 (4): 1. doi:10.1080/14789941003596981.  edit
  36. ^ James, D. V.; Mullen, P. E.; Pathé, M. T.; Meloy, J. R.; Preston, L. F.; Darnley, B.; Farnham, F. R. (2009). "Stalkers and harassers of royalty: the role of mental illness and motivation". Psychological Medicine 39 (9): 1479–1490. doi:10.1017/S0033291709005443. PMID 19335930.  edit
  37. ^ Dressing, Harald; Kuehner, Gass (2005). "Lifetime prevalence and impact of stalking in a European population. Epidemiological data from a middle-sized German city". The British Journal of Psychiatry. Retrieved 2006-12-12. 
  38. ^ Tjaden, Patricia; Nancy Thoennes (1998). "Stalking in America: Findings from the National violence against women survey" (in Englisch). National Violence Against Women Survey. Retrieved 2006-12-12. 
  39. ^ Section 264 of the Criminal Code of Canada
  40. ^ Department of Justice of Canada - Review and Backgrounder on section 264[dead link]
  41. ^ Department of Justice - Criminal Harassment[dead link]
  42. ^ "Kin of stalking victim seek justice". The Japan Times. 2003-06-12. Retrieved 2008-02-14. 
  43. ^
  44. ^
  45. ^ Are You Being Stalked?
  46. ^ Stalking by Rhonda Saunders
  47. ^ a b Bill Analysis by Bill Lockyer
  48. ^ Culture of Patriarchy in Law: Violence From Antiquity to Modernity
  49. ^ a b c Judge John Watson profile
  50. ^ Domestic Violence Stalking by Nancy Lemon
  51. ^ DPPA and the Privacy of Your State Motor Vehicle Record
  52. ^ U.S. Senate Committee: Robert Douglas Testimony
  53. ^ "United States Code: Title 10,920a. Art. 120a. Stalking -- LII / Legal Information Institute". Retrieved 2011-08-28. 
  54. ^ The New Article 120, UCMJ

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