Missouri Revised Statutes

Mo. Rev. Stat. § 105.530 (2026)

✓ current as of May 2026
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  *105.530.  Law not to be construed as granting right to strike. — Nothing contained in sections 105.500 to 105.598 shall be construed as granting a right to public employees covered in sections 105.500 to 105.598 to strike.

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(L. 1965 p. 232 § 4, A.L. 1967 p. 192 § 105.540, A.L. 2018 H.B. 1413)

*Revisor's Note:  On June 1, 2021, this section was declared unconstitutional in Missouri National Education Association v. Missouri Department of Labor and Industrial Relations, 623 S.W.3d 585 (Mo.banc).

(1977) Teachers' strike while not covered by statute is illegal as violative of common law. School Dist. of Kansas City v. Clymer (A.), 554 S.W.2d 483.

(1987) This statute does not give rise to any implied right of action on behalf of citizens whose home was destroyed during strike by fire fighters' union.  White v. Intern. Ass'n. of Fire Fighters, 738 S.W.2d 933 (Mo. App.).

(2021)  House Bill 1413 enacted in 2018 held invalid as violation of equal protection clause of Article I, Section 2 of state constitution; section as amended by that act could not be severed from rest of bill.  Missouri National Education Association v. Missouri Department of Labor and Industrial Relations, 623 S.W.3d 585 (Mo.banc).

Notes of Decisions
Cited in 17 cases (2 in the last 5 years), 1969–2022 · leading case: State Ex Inf. Ashcroft v. Kansas City Firefighters Local No. 42, 672 S.W.2d 99 (Mo. Ct. App. 1984).
State Ex Inf. Ashcroft v. Kansas City Firefighters Local No. 42, 672 S.W.2d 99 (Mo. Ct. App. 1984). · cites it 10× “That sufficiently answers the contention of the defendant Firefighters that the strike is so indispensable a tool of the worker self-betterment society values that the work stoppage, although a technical breach of the statute, remains a justified means to that end.”
Indep.-Nat'l Educ. Ass'n v. Indep. Sch. Dist., 223 S.W.3d 131 (Mo. 2007). · cites it 4× “on 29, Article I, of the 1945 Constitution to employees in private industry and in the sense that term is usually known with its attendant connotation of unfair labor practice for refusal by the employer to execute and adopt the agreement produced by bargaining, and the use of…”
St. Louis Teachers Ass'n v. Bd. of Educ., 544 S.W.2d 573 (Mo. 1976). · cites it 14× “On Sunday, February 18, 1973, the Board and the Association, through their attorneys, reached a settlement of their differences.”
Vorbeck v. McNeal, 407 F. Supp. 733 (E.D. Mo. 1976). · cites it 6× “Such a legislative remedy has already been enacted in Missouri by Section 105.530, R.S.Mo., 1969, which withholds the right to strike from all public employees.”
State Ex Rel. Missey v. City of Cabool, 441 S.W.2d 35 (Mo. 1969). · cites it 4× “Section 105.530, supra. These provisions express the right of the appellant employees of Cabool to do those things mentioned in their petitions: to join a labor union such as IBEW Local 2 and, as an appropriate unit, to *41 designate, select and have Local 2 as a representative…”
Missouri Nat'l Educ. Ass'n v. Missouri State Bd. of Mediation, 695 S.W.2d 894 (Mo. 1985). · cites it 2× “The right to strike is specifically excluded, § 105.530, and is inappropriate in the public sector.”
State Ex Rel. O'Leary v. Missouri State Bd. of Mediation, 509 S.W.2d 84 (Mo. 1974). · cites it 4× “” Section 105.530, in part, provides that the rights conferred shall not “be construed as granting a right to employees covered in sections 105.”
Sch. Dist. of Kansas City v. Clymer, 554 S.W.2d 483 (Mo. Ct. App. 1977). · cites it 2× “It is without question, however, that the teachers’ strike was illegal. It was so conceded by respondent’s counsel in argument before this court.”
Curators of the Univ. of Missouri v. Pub. Serv. Employees Local No. 45, 520 S.W.2d 54 (Mo. 1975). · cites it 2× “2d 763 , but expressly denied by Section 105.530, supra, to public employees.”
Willis v. Sch. Dist. of Kansas City, 606 S.W.2d 189 (Mo. Ct. App. 1980). · cites it 2× “That the strike action is prohibited and hence illegal under Missouri law, see § 105.530, RSMo 1978. That teachers are prohibited from forming and joining labor organizations, see § 105.”
Parkway Sch. Dist. v. Parkway Ass'n of Educ., Support Pers., Local 902/MNEA, 807 S.W.2d 63 (Mo. 1991). · cites it 2× “See § 105.530, RSMo 1986. With this exception, the process of choosing representatives and conducting negotiations resembles the procedures available under the federal labor relations statutes.”
City of Webster Groves v. Institutional & Pub. Employees Union, 524 S.W.2d 162 (Mo. Ct. App. 1975). · cites it 2× ““ * * * A regular employee leaving the city’s service shall be compensated for vacation leave accrued to the date of separation only if he has complied with the provisions of Section 11.”
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