September 7, 2026  /  Legal Analysis

A Missouri Congressman Co-Sponsored the Flock-Off Act. Missouri Still Has No License Plate Camera Law.

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On September 2, a bipartisan group of members of the United States House introduced a bill that would cut off federal money for the automated license plate reader cameras now mounted along roads across the St. Louis region. One of the two lead sponsors represents Missouri. The bill has a long road ahead of it, and in the meantime Missouri law on these cameras is thinner than most residents assume.

Status check. H.R. 10221 was introduced on September 2, 2026 and referred to committee. It is not law, and nothing about how license plate data is collected, stored, or searched in Missouri changed this month because of it. The practical developments for Missouri residents happened elsewhere, in a United States Supreme Court decision issued in June and in a local police department’s audit findings in August.

Automated license plate readers, usually shortened to ALPRs, photograph passing vehicles, read the plate by software, and send the plate number with a time stamp, a location, and often a vehicle description to a searchable database. Flock Safety is the best known vendor, and its solar-powered units are a familiar sight along arterial roads in St. Charles County, St. Louis County, and dozens of smaller Missouri municipalities. The individual photograph is unremarkable. The database is what raises the legal questions, because it converts scattered public observations of a car into a retrospective record of where that car has been.

What the Flock-Off Act would actually do

The bill is H.R. 10221, titled the Flock-Off Act. Representative Thomas Massie of Kentucky and Representative Eric Burlison, who represents Missouri’s Seventh Congressional District in the southwest corner of the state, are the lead sponsors. The original cosponsors listed by Representative Massie’s office are Representatives Lauren Boebert, Paul Gosar, Ro Khanna, Chip Roy, and Victoria Spartz. That grouping is worth noting on its own terms. Surveillance policy is one of the few areas in which legislators who agree on very little else file the same bill.

The operative provision is a funding restriction rather than a ban. Section 2 provides that no federal funds may be used to purchase, lease, install, operate, or maintain a “covered camera system,” and bars federal agencies from contracting for the operation of such systems or for access to their data. A covered camera system is defined as a device that automatically captures and processes images using machine learning to extract either plate numbers and vehicle data or biometric data from individuals, and then transmits that information to a remote system for storage and analysis. Biometric data is defined to include facial images, voiceprints, fingerprints, iris scans, and gait patterns.

Two enforcement features go further than a simple appropriations rider. The bill would require agencies to decommission existing federally funded systems within 180 days, and it directs that future federal funds be withheld from a violating recipient until the improperly obligated or expended money is repaid to the Treasury. Two carve-outs survive: camera systems within one mile of a United States border used for border security, and license plate readers used solely for toll collection.

What the bill does not do

It does not prohibit a city, county, or private business from buying cameras with its own money.

It does not create a warrant requirement, a retention limit, or an audit obligation.

It does not give an individual a right to sue over a search of plate data. Any remedy would still come from the Fourth Amendment, from Article I, Section 15 of the Missouri Constitution, or from a state statute that does not yet exist.

Missouri has no general statute on license plate readers

This surprises people. Missouri’s statutes do not contain a general framework governing who may deploy an automated license plate reader, how long the data may be kept, who may query it, or what happens when someone queries it for a personal reason. Bills to create one have been filed in session after session and have not passed.

In the 2026 regular session, Senator Rick Brattin filed Senate Bill 1027, which would have created a new Section 590.1000 barring political subdivisions and state agencies from using automated license plate reader systems or accessing captured plate data from vehicles on a public highway, subject to exceptions for readers affixed to vehicles occupied by a peace officer and for data used in connection with Missouri’s motor vehicle financial responsibility verification program under Sections 303.420 to 303.440. It was read a second time, referred to the Senate Transportation, Infrastructure and Public Safety Committee, and went no further.

From the other side of the aisle, Representative LaKeySha Bosley of St. Louis filed House Bill 3192, the Missouri Automatic License Plate Reader Regulation Act. That bill regulated rather than prohibited, limiting use to criminal investigations, missing person cases, and stolen vehicle alerts, barring general surveillance and monitoring of lawful activity, requiring deletion of data within thirty days unless tied to an active investigation, and requiring annual public reporting. It was referred to the House Emerging Issues Committee and did not reach a floor vote before the General Assembly adjourned.

The result is that the operative rules in Missouri today are not statutory. They are whatever an individual police department has written into its own policy and whatever a vendor contract requires, backed by the constitutional floor.

Missouri’s constitution says more than the Fourth Amendment does

Missouri voters amended Article I, Section 15 of the state constitution on August 5, 2014. The amended section, effective September 5, 2014, twelve years ago this month, reads in relevant part that the people shall be secure in their persons, papers, homes, effects, “and electronic communications and data,” from unreasonable searches and seizures, and that no warrant shall issue to “access electronic data or communication” without describing the data to be accessed and without probable cause supported by written oath or affirmation.

That text is unusual. Most state search and seizure provisions track the federal language, while Missouri’s expressly names electronic data as a protected category and expressly contemplates a warrant to access it. Whether a query of a commercial plate database is an access of “electronic data” within the meaning of Section 15 is a serious question, and as of this writing Missouri’s appellate courts have not produced a decision squarely deciding it. The argument is available and untested rather than foreclosed.

The Supreme Court’s June decision changed the framing

On June 29, 2026, the Supreme Court decided Chatrie v. United States, No. 25-112, by a vote of five to four, with Justice Kagan writing for the majority. The case involved a geofence warrant seeking Google Location History data. The syllabus states the holding plainly: police officers conducted a Fourth Amendment search when they acquired the location data from Google, because an individual has a reasonable expectation of privacy in his cell phone location information.

The Court reasoned that location history is not truly shared in the ordinary sense, because it is the automatic price of conventional cell phone usage rather than something voluntarily exposed to a third party.

That reasoning matters to license plate readers for one specific purpose. The government’s traditional answer to an ALPR challenge is that a car on a public road is exposed to anyone who cares to look, so no privacy interest attaches. Chatrie does not overturn that idea, and it did not involve cameras on public streets. What it does is reinforce a distinction that has been building since Carpenter v. United States in 2018: the constitutional question is not only whether a single observation was public, but whether the aggregated, retrospective, searchable record of many observations reveals something the government could not practically have obtained by watching.

Prosecutors will argue that plate data is categorically different from a phone in a pocket, because the plate is a state-issued identifier displayed by legal requirement on a public road. Defense counsel will argue that a database holding billions of reads a month produces exactly the mosaic the Court has grown wary of. Neither argument has a settled answer in Missouri.

What happened in St. Charles County

The most instructive recent development for St. Louis area residents was not a court ruling. On August 22, 2026, the St. Charles County Police Department announced it was discontinuing its Flock camera program. According to the department’s account, reported by KCUR, an audit tool flagged an abnormal pattern of searches by a former civilian employee, who acknowledged using the system for personal reasons unrelated to law enforcement. The employee’s credentials were suspended, the employee was placed on unpaid leave and resigned after receiving a termination notice, and an outside agency was asked to investigate. The department took its twenty-eight cameras out of service, restricted access to historical data to a small number of supervisors and intelligence officers, and committed to regular auditing. Chief Kurt Frisz characterized the episode as an example of accountability working, noting that the department detected the problem, acted on it, and told the public.

Reasonable people read that story differently. One reading is that the audit function did its job. Another is that a system holding the movement history of an entire county is only as safe as the people permitted to query it. Both readings point to the same conclusion: access control, logging, and audit obligations are doing most of the real work here, and in Missouri those obligations come from policy and contract rather than from statute.

If you are facing charges that began with a camera

A growing share of traffic stops and investigations begin with an ALPR alert rather than an officer’s own observation, and that changes what a defense lawyer needs to ask for. The relevant questions include whether the plate was read correctly, whether the “hot list” entry that generated the alert was current and accurate at the moment of the read, who queried the database and under what stated purpose, whether the query was logged, whether the agency’s written policy permitted it, and whether the stop rested on the alert alone or on independent observation.

Those records exist. Audit logs are a standard feature of these systems, as the St. Charles County episode demonstrates. They are rarely produced unless someone asks for them specifically and early. Our firm handles criminal defense and traffic matters throughout the St. Louis region, and the discovery strategy in a camera-initiated case looks different from a conventional stop.

If your business or association is considering cameras

Homeowners associations, apartment communities, retail centers, and industrial parks are installing these systems rapidly, often with an option to share the feed with local police. That decision carries obligations the vendor’s sales material does not usually address.

Questions to resolve before signing

Who owns the captured data, and what happens to it if the contract ends.

How long the vendor retains it, and whether the retention period can be shortened by agreement.

Which outside agencies can query the feed, whether that list can grow without your consent, and whether you receive an audit report.

Who bears the cost and liability if an employee, a board member, or a shared agency misuses the system.

Whether your governing documents actually authorize the expenditure and the data sharing, which is a recurring problem for associations.

For a public body, whether the resulting records are open under Missouri’s Sunshine Law and who will handle the requests.

These are ordinary contract, governance, and risk allocation questions, and they are considerably easier to negotiate before installation than after an incident. We work through them with clients on the business law and technology and AI law side of the practice, and the civil rights exposure when a system is misused is not theoretical.

What to watch over the next several months

Three things are worth tracking. The first is whether H.R. 10221 receives a committee hearing; a bill with sponsors drawn from opposite ends of the House is not automatically a bill that moves, and most introduced bills never do. The second is the Missouri General Assembly’s 2027 regular session, which convenes in January. ALPR bills have now been filed by both Republican and Democratic members, and a Missouri police department has publicly reported a misuse incident. The third is local, because municipal boards and county councils across the region are the bodies actually voting on renewals.

Helpful resources

The coverage below is drawn from several vantage points and labeled by ownership, so you can weigh each account and reach your own conclusion.

Text of H.R. 10221, the Flock-Off Act · posted by the office of a lead sponsor, United States House of Representatives. Primary source for the bill language.

Sponsors’ announcement of the bill · official press release from Representative Massie’s congressional office. Written to advocate for the bill.

Chatrie v. United States, No. 25-112 (June 29, 2026) · slip opinion published by the Supreme Court of the United States. Primary source.

Missouri Constitution, Article I, Section 15 · Missouri Revisor of Statutes, State of Missouri. Primary source.

Missouri Senate Bill 1027 (2026) · Missouri Senate official bill tracking. Primary source.

Report on the St. Charles County misuse finding · KCUR, a nonprofit NPR member station licensed to the University of Missouri–Kansas City.

Coverage of the 2026 Missouri bills · First Alert 4 (KMOV), a commercial St. Louis television station owned by Gray Media.

Running list of Missouri municipalities ending Flock contracts · Show-Me Institute, a Missouri free-market policy organization. Advocacy source, useful for the municipal tally.

Related on this site: Who controls the St. Louis Police?

Questions about a camera-initiated stop, or about a camera contract

Whether you are defending a charge that began with a license plate alert or advising a board that has been asked to sign a surveillance agreement, an early conversation is worth having.

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This article is provided for general educational purposes only. It is not legal advice and it is not tax advice, and reading it does not create an attorney-client relationship with Haake Law Group PC or with Derek R. Haake. Legislation, court decisions, agency policy, and local ordinances change, and the analysis above reflects publicly available information as of September 7, 2026. Verify any statute, bill status, or court decision against the primary source before relying on it, and consult a licensed attorney about your specific situation.

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