William & Mary Journal of Race, Gender, and Social Justice


Beatings by men are the leading cause of injury for American women.' Many people ask why these women do not leave their batterers. The answer often has its roots in the crime of stalking. As the mother of a battered woman who was stalked and murdered by her abuser explains, "People ask 'Why don't battered women leave?' They get killed. That's why."2 Unwilling to relinquish control, "batterers [can] become stalkers, pursuing their victims after the victims leave the abusive relationship."3 Stalking is a problem faced not only by domestic violence victims or women in general. Virtually anyone can fall prey to a stalker.

First, this Comment will define stalking and explain the urgency of the issue. Second, it will discuss and evaluate the stalking laws developed by the states. Third, it will -compare the state laws with the National Institute of Justice Model Anti- Stalking Code for States in order to determine which provisions best protect stalking victims.