Missouri
Missouri Police Bodycam Laws (2026): Active vs. Inactive Rule
Missouri has no statute requiring police to wear body cameras, but it has one of the country's more distinctive rules for what happens to the footage once it exists. Under Mo. Rev. Stat. section 610.100, mobile video recordings stay closed while the underlying investigation is active and open once it becomes inactive.
Information last verified on 2026-07-08. This article has not yet been reviewed by a licensed lawyer.
Jurisdiction scope: This article addresses Missouri law under Mo. Rev. Stat. section 610.100 (Missouri's Sunshine Law), as verified on 2026-07-08. It does not address whether a civilian may lawfully record an on-duty police officer; that question is settled separately and covered in Is It Illegal to Record Someone in Public?. This page addresses the reverse question: what happens to footage Missouri police record of the public.
Does Missouri require police to wear body cameras?
No. Missouri has no statute compelling any city, county, or state law enforcement agency to purchase or issue body cameras. Whether a department in Missouri uses them, and how many officers carry one, is a local budget and policy decision, the same as in most states without a bodycam-specific mandate. What Missouri does have is a detailed statute governing what happens once an agency records something: Mo. Rev. Stat. section 610.100, part of the state's open-records law known as the Sunshine Law. Missouri added the term "mobile video recordings," covering both dashcam and bodycam data, to that statute effective August 28, 2016, and has revised the disclosure and penalty provisions since, most recently in a version effective August 28, 2020.
What is Missouri's active versus inactive rule?
This is the framework that sets Missouri apart from most other states. Under section 610.100.2(2), mobile video recordings and investigative reports of any Missouri law enforcement agency are closed records while the underlying investigation is active. They become open records once the investigation becomes inactive. The statute defines "inactive" to mean one of three things has happened: the law enforcement agency has decided not to pursue the case; the statute of limitations to file charges has run, or ten years have passed since the offense, whichever comes first; or every person convicted based on the investigation has exhausted their appeals and the convictions are final. In practice, this means a bystander who requests bodycam footage the week after an incident will usually be told the case is still open, while the same request filed years later, after the case is formally closed, generally must be granted unless another exemption applies.
Can I get a copy of footage of myself, even during an active investigation?
Yes, in most cases. Section 610.100.2(4) lets a person who appears in a mobile video recording, along with that person's attorney or insurer, request and receive a complete, unaltered, unedited copy on written request, regardless of whether the investigation is still active. This is a narrower right than general public access, but it matters for someone involved in a traffic stop, an arrest, or a use-of-force incident who wants their own footage right away rather than waiting for the case to close.
What gets redacted, even from open footage?
Section 610.100.3 requires an agency to redact portions of a recording that are reasonably likely to pose a clear and present danger to the safety of a victim, witness, or undercover officer, or that would jeopardize an active criminal investigation or reveal law enforcement investigative techniques and procedures. This redaction duty applies on top of the active/inactive rule, so even footage that has become an open record under the inactive-investigation trigger can still come back with sensitive portions blacked out or muted.
Are there special rules for footage recorded inside a home?
Yes. When a mobile video recording captures a nonpublic location, such as the inside of a residence, a recipient who obtains the footage cannot display or disclose it, including describing what it shows, without first giving direct notice to each non-law-enforcement person whose image or voice appears in it. Those individuals then get a window to seek a court order blocking the disclosure before the recipient can share it further. This layer exists specifically because mobile video recordings often capture people inside their own homes who were never suspects in anything.
What happens if an agency wrongly withholds footage?
Missouri's Sunshine Law has real teeth here, and a 2026 case shows it. On August 27, 2023, a Stoddard County sheriff's deputy shot and killed a family's dog during a call. The Pennington family requested the deputy's bodycam footage within days, but Sheriff Carl Hefner refused, citing an active investigation and safety concerns. The video was not released for roughly eight months, and even then it came from the county prosecutor rather than the sheriff. The family sued, and a trial court found Hefner committed a knowing violation of the Sunshine Law, in part because the department failed to timely justify continued closure of the record, and imposed a $500 civil penalty plus $817.50 in deposition costs and $5,000 in attorney fees. The Missouri Court of Appeals, Southern District, affirmed that judgment in February 2026 in The Oliver Firm, L.C. v. Hefner, No. SD38762, rejecting the sheriff's argument that the civil penalty provision applied only to incident and arrest reports rather than to mobile video recordings themselves. The case confirms that "active investigation" is not a magic phrase that lets an agency sit on footage indefinitely; the statute's own definition of inactive, and its penalty provisions, apply whether or not an agency wants them to.
What penalties apply for violating the disclosure rules?
Section 610.100 sets escalating civil penalties. A knowing violation, where the public body knew its refusal violated the Sunshine Law, carries a penalty up to $1,000. A purposeful violation carries a penalty up to $5,000. In both cases, a court can also award the requester's costs and reasonable attorney fees, which is what happened in the Hefner case above. A requester who is denied access can also ask a circuit court to order disclosure directly rather than waiting for the investigation to become inactive on its own.
Frequently asked questions
Disclaimer
This article provides general legal information about Missouri law governing police body cameras and public access to footage, as verified on 2026-07-08. It does not constitute legal advice and does not create an attorney-client relationship. Readers should consult a lawyer licensed in Missouri for advice about a specific records request or incident.
Related articles
- Police Bodycam Laws by State: the complete hub
- Is It Illegal to Record Someone in Public?
- Missouri Recording Laws: One-Party Consent Rules
Last updated: 2026-07-08. Statutes cited reflect their in-force version as of 2026-07-08.
Frequently Asked Questions
Does Missouri require police departments to use body cameras?
No. There is no Missouri statute mandating body cameras for any law enforcement agency. Mo. Rev. Stat. section 610.100 only governs what happens to footage that an agency chooses to record; it does not require the recording to happen in the first place.
When does Missouri bodycam footage become a public record?
Once the underlying investigation becomes 'inactive' under Mo. Rev. Stat. section 610.100.2(2): the agency decides not to pursue the case, the statute of limitations or ten years passes (whichever is first), or all resulting convictions become final after appeals.
Can I get bodycam footage of my own arrest while the case is still open in Missouri?
Often yes. Section 610.100.2(4) lets the person depicted, or their attorney or insurer, request a complete, unaltered copy even during an active investigation, separate from the general public-access rule.
What happens if a Missouri sheriff or police department refuses to release footage it should have released?
A requester can sue. Courts have found knowing or purposeful violations of section 610.100, which carry civil penalties up to $1,000 or $5,000 respectively, plus attorney fees, as in the 2026 Missouri Court of Appeals decision in The Oliver Firm, L.C. v. Hefner, No. SD38762.
Does Missouri redact bodycam footage even after a case closes?
Yes. Section 610.100.3 requires redaction of material that would endanger a victim, witness, or undercover officer, or that would reveal investigative techniques, regardless of whether the recording has otherwise become an open record.
Do I need to notify people before sharing Missouri bodycam footage recorded inside a home?
Yes. If the footage was recorded in a nonpublic location, the recipient must give direct notice to each non-law-enforcement person shown in it before displaying or disclosing the recording further, giving that person a chance to seek a court order first.
Does an officer need my consent to record me on a body camera in Missouri?
No. Missouri is a one-party consent state for recording, and an on-duty officer recording a member of the public raises no consent issue under state wiretap law at all.
Sources and References
- Mo. Rev. Stat. section 610.100, arrest and incident records, mobile video recordings, closed records until investigation inactive(revisor.mo.gov).gov
- Missouri Attorney General, Sunshine Law FAQs(ago.mo.gov).gov
- The Missouri Bar, Law enforcement navigation of Missouri's Sunshine Law(news.mobar.org)
- Missouri Lawyers Media, Appeals court backs trial ruling in bodycam Sunshine Law case (The Oliver Firm, L.C. v. Hefner, No. SD38762)(molawyersmedia.com)
- Lewis Rice, Missouri Revises Its Sunshine Law to Address Mobile Video Recordings(lewisrice.com)