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Missouri Revised Statutes

Mo. Rev. Stat. § 168.106 (2026)

Indefinite contract, what affects

✓ current as of May 2026
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  168.106.  Indefinite contract, what affects. — The contract between a school district and a permanent teacher shall be known as an indefinite contract and shall continue in effect for an indefinite period, subject only to:

  (1)  Compulsory or optional retirement when the teacher reaches the age of retirement provided by law, or regulation established by the local board of education;

  (2)  Modification by a succeeding indefinite contract or contracts in the manner hereinafter provided;

  (3)  The death of the teacher;

  (4)  Resignation of the teacher with the written consent of the school board;

  (5)  Termination by the board of education after a hearing as hereinafter provided; and

  (6)  The revocation of the teacher's certificate.

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(L. 1969 p. 275 § 168.103)

Notes of Decisions
Cited in 22 cases, 1972–2014 · leading case: Hudson v. Marshall, 549 S.W.2d 147 (Mo. Ct. App. 1977).
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Hudson v. Marshall, 549 S.W.2d 147 (Mo. Ct. App. 1977). · cites it 4× “Section 168.106 of the Teacher Tenure Act deals with six matters which affect the continuation of an indefinite contract.”
Keesee v. Meadow Heights R-II Sch. Dist., 865 S.W.2d 818 (Mo. Ct. App. 1993). · cites it 4× “1990, holding an indefinite contract, § 168.106, RSMo 1986, with Meadow Heights R-II School District ("the District").”
Jackson Cnty. Bd. of Election Commissioners Ex Rel. Brown v. City of Lee's Summit, 277 S.W.3d 740 (Mo. Ct. App. 2008). · cites it 2× “See § 168.106, RSMo 2000. If the tenured teacher had raised claims similar to those posed here, the claims would survive to receive appellate review.”
Thruston v. Jefferson City Sch. Dist., 95 S.W.3d 131 (Mo. Ct. App. 2003). · cites it 2× “See § 168.106, RSMo 2000. If the tenured teacher had raised claims similar to those posed here, the claims would survive to receive appellate review.”
Lindbergh Sch. Dist. v. Syrewicz, 516 S.W.2d 507 (Mo. Ct. App. 1974). · cites it 4× “A contract between a permanent teacher and the school district is for an indefinite time, § 168.106, and continues in effect for an indefinite period subject to certain enumerated exigencies of which only two would be applicable here: (1) resignation of the teacher with the…”
Lopez v. Vance, 509 S.W.2d 197 (Mo. Ct. App. 1974). · cites it 2× “" § 168.106 provides that "The contract between a school district and a permanent teacher shall be known as an indefinite contract and shall continue in effect for an indefinite period, subject only to: [certain specified reasons.”
Sadler v. Bd. of Educ. of Cabool Sch. Dist. R-4, 851 S.W.2d 707 (Mo. Ct. App. 1993). · cites it 2× “In § 168.106 the term “indefinite contract” is clearly defined as being a contract between a school district and a “permanent teacher,” thereby excluding from its meaning any contract for extra or extended duties.”
Campbell v. Reorganized Sch. Dist. No. 1, 904 S.W.2d 18 (Mo. Ct. App. 1995). · cites it 11× “The appellant teachers claim that the court’s decision violates section 168.106 of the Teacher Tenure Act because the extra month provision was a part of each teacher’s tenured contract and was not removable from the contract without the consent of the teacher.”
Loeffelman v. Bd. of Educ., 134 S.W.3d 637 (Mo. Ct. App. 2004). · cites it 2× “Section 168.106(5). 3 . The questions occurred about twenty minutes into the class period.”
Elam ex rel. Waynesville R-VI Sch. Dist. v. Waynesville R-VI Sch. Dist., 676 S.W.2d 880 (Mo. Ct. App. 1984). · cites it 3× “110 provides a district may modify an indefinite contract annually on or before the 15th day of April by “[fjixing the amount of annual compensation for the following school year as provided by the salary schedule adopted by the board of education applicable to all teachers.”
Hubbard v. Lincoln Cnty. R-III Sch. Dist., 23 S.W.3d 762 (Mo. Ct. App. 2000). · cites it 2× “The school’s Extended Sick Leave policy (policy) is incorporated into the contract by reference.”
Dameron v. Bd. of Educ. of the Lebanon Sch. Dist. R-3, 549 S.W.2d 671 (Mo. Ct. App. 1977). “§ 168.106 provides, in essence, that the indefinite contract between a permanent teacher and a school district “shall continue in effect for an indefinite period,” subject only to six conditions, one of which is: “(5) Termination by the board of education after a hearing as…”
Show all 22 citing cases →
— Mo. Rev. Stat. § 168.106(2) — 1 case
Robert v. Kelso C-7 Missouri Pub. Sch. Dist., 946 S.W.2d 241 (Mo. Ct. App. 1996).
— Mo. Rev. Stat. § 168.106(4) — 1 case
Hudson v. Marshall, 549 S.W.2d 147 (Mo. Ct. App. 1977). “Section 168.106 of the Teacher Tenure Act deals with six matters which affect the continuation of an indefinite contract.”
— Mo. Rev. Stat. § 168.106(5) — 2 cases
Loeffelman v. Bd. of Educ., 134 S.W.3d 637 (Mo. Ct. App. 2004). “Section 168.106(5). 3 . The questions occurred about twenty minutes into the class period.”
Hudson v. Marshall, 549 S.W.2d 147 (Mo. Ct. App. 1977). “Section 168.106 of the Teacher Tenure Act deals with six matters which affect the continuation of an indefinite contract.”
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