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Various approaches have been made to criminalize stalking, and a plethora of descriptors now identify the stalking criminal act. In the majority of jurisdictions, the criminal act element required for stalking includes any course of conduct that credibly threatens the victim’s safety, including following, 1 harassing, 2 approaching, 3 pursuing, or making an express or implied threat to injure the victim, the victim’s family member,4 or the victim’s property. 5 In general, credible threat means the defendant has the apparent ability to effectuate the harm threatened. 6 The stalking criminal act is unique among criminal acts in that it must occur on more than one occasion or repeatedly. 7
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