Missouri has become the first state to provide explicit constitutional protection for “electronic communications and data,” prohibiting “unreasonable searches and seizures” of such information and requiring a warrant.  Senate Joint Resolution No. 27 was passed by the Missouri General Assembly in May and was overwhelmingly approved by voters last week.  The constitutional amendment addresses issues that have caused a great deal of confusion among federal courts considering whether the Fourth Amendment to the U.S. Constitution or the Electronic Communications Privacy Act (ECPA) requires a warrant for the content of all electronic communications or for non-content data, and how specific a warrant must be in describing the electronic data to be seized.  The language of the Missouri amendment is very general, so its application will depend on how it is interpreted by Missouri courts.