Missouri Revised Statutes

Mo. Rev. Stat. § 168.114 (2026)

Board may terminate, grounds for

✓ current as of May 2026
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  168.114.  Board may terminate, grounds for. — 1.  An indefinite contract with a permanent teacher shall not be terminated by the board of education of a school district except for one or more of the following causes:

  (1)  Physical or mental condition unfitting him to instruct or associate with children;

  (2)  Immoral conduct;

  (3)  Incompetency, inefficiency or insubordination in line of duty;

  (4)  Willful or persistent violation of, or failure to obey, the school laws of the state or the published regulations of the board of education of the school district employing him;

  (5)  Excessive or unreasonable absence from performance of duties; or

  (6)  Conviction of a felony or a crime involving moral turpitude.

  2.  In determining the professional competency of or efficiency of* a permanent teacher, consideration should be given to regular and special evaluation reports prepared in accordance with the policy of the employing school district and to any written standards of performance which may have been adopted by the school board.

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(L. 1969 p. 275 § 168.107)

*Word "of" omitted in original rolls.

CROSS REFERENCE:

Suspension or termination of contracts of certificated staff and administrators, academically deficient schools, when, procedure, 160.540

(1975) Evidence held sufficient to justify dismissal for incompetency, insufficiency and insubordination. Saunders v. Reorganized School District No. 2 of Osage City (Mo.), 520 S.W.2d 29.

(1976) School board is not required to have an official, published regulation on absences in order to discharge a permanent teacher for "excessive" and "unreasonable" absences.  Aubuchon v. Gasconade Co. R-1 School District (A.), 541 S.W.2d 322.

(1991)  Where charges against teacher compromised teacher's integrity and respect in classroom, immoral conduct for purposes of statute providing for termination of teacher is not limited to sexual conduct but includes other conduct, such as theft of school property.  Nexus must exist between teacher's fitness to teach and immoral conduct. Cochran v. Board of Education, 815 S.W.2d 55 (Mo.App.E.D.).

Notes of Decisions
Cited in 55 cases, 1972–2020 · leading case: Ross v. Robb, 651 S.W.2d 680 (Mo. Ct. App. 1983).
Ross v. Robb, 651 S.W.2d 680 (Mo. Ct. App. 1983). · cites it 22× “, to-wit, I *686 concur that the constitutionality of § 168.114, RSMo 1978 was adequately raised but dissent as to that part which construes § 536.”
Harrisburg R-VIII Sch. Dist. v. O'Brian, 540 S.W.2d 945 (Mo. Ct. App. 1976). · cites it 16× “Sub-paragraph (5) of paragraph 1 of Section 168.114, RSMo 1969, sets forth one of several statutory grounds, which, if violated, constitutes cause for termination of a permanent teacher’s indefinite contract: “(5) Excessive or unreasonable absence from performance of duties; .”
Thompson v. Sw. Sch. Dist., 483 F. Supp. 1170 (W.D. Mo. 1980). · cites it 12× “Further, § 168.114 1 must be read in conjunction with § 168.”
Willis v. Sch. Dist. of Kansas City, 606 S.W.2d 189 (Mo. Ct. App. 1980). · cites it 20× “The pertinent statutory authority to the instant case is to be found within § 168.114, RSMo 1978. The procedural aspects of termination are to be found within §§ 168.”
Burgess v. Ferguson Reorganized Sch. Dist., R-2, 820 S.W.2d 651 (Mo. Ct. App. 1991). · cites it 12× “1980), which dealt with the constitutionality of Section 168.114, the court stated that teachers employed under an indefinite contract have acquired a property interest in their employment so that “failure to fairly warn these individuals of the proscribed conduct might clearly…”
Clark v. Bd. of Directors of the Sch. Dist., 915 S.W.2d 766 (Mo. Ct. App. 1996). · cites it 5× “In rendering its decision, as required by § 168.114 RSMo 1994, 1 the Board of Directors (“Board”) concluded that, based on substantial evidence, appellant “willfully and/or persistently failed to obey the published regulations of the Board .”
Ross v. Robb, 662 S.W.2d 257 (Mo. 1983). · cites it 3× “The Court of Appeals, Western District, transferred the case after opinion, holding that it lacked jurisdiction to assess petitioner’s allegation of constitutional infirmity of section 168.114, RSMo 1978. Ross v. Robb, 651 S.”
Hagely v. Bd. of Educ. of Webster Groves Sch. Dist., 841 S.W.2d 663 (Mo. 1992). · cites it 2× “1 should apply only within the context of §§ 168.114 through 168.120. Consequently, appellants assert that the time limitation of § 168.”
Lindbergh Sch. Dist. v. Syrewicz, 516 S.W.2d 507 (Mo. Ct. App. 1974). · cites it 8× “The grounds for termination of a permanent teacher's contract are enumerated in § 168.114. Plaintiff contends that the defendant was not "terminated" as that term is used in § 168.”
Westbrook v. Bd. of Educ. of City of St. Louis, 724 S.W.2d 698 (Mo. Ct. App. 1987). · cites it 5× “We first note that Section 168.114 RSMo 1978, the general statute dealing with when a permanent teacher may be discharged, 2 does require that before a teacher may be discharged for violating Board regulations, the teacher’s violation of the regulations must be shown to be…”
Stewart v. Bd. of Educ., 574 S.W.2d 471 (Mo. Ct. App. 1978). · cites it 4× “Section 168.114. As pertinent to this case, the last cited section provides: “An indefinite contract with a permanent teacher shall not be terminated by the board of education of a school district except for one or more of the following causes: .”
Lacks v. Ferguson Reorganized Sch. Dist., R-2, 936 F. Supp. 676 (E.D. Mo. 1996). · cites it 7× “Mo.Rev.Stat. § 168.114(1). Terminated teachers can appeal the decision of the board to the circuit court of the county where the employing district is located, and such appeals "shall be heard as provided in chapter 536, RSMo.”
— Mo. Rev. Stat. § 168.114(1) — 2 cases
Lacks v. Ferguson Reorganized Sch. Dist., R-2, 936 F. Supp. 676 (E.D. Mo. 1996). “Mo.Rev.Stat. § 168.114(1). Terminated teachers can appeal the decision of the board to the circuit court of the county where the employing district is located, and such appeals "shall be heard as provided in chapter 536, RSMo.”
Christy v. Bd. of Educ., 694 S.W.2d 280 (Mo. Ct. App. 1985).
— Mo. Rev. Stat. § 168.114(1)(4) — 1 case
Lacks v. Ferguson Reorganized Sch. Dist., R-2, 936 F. Supp. 676 (E.D. Mo. 1996). “Mo.Rev.Stat. § 168.114(1). Terminated teachers can appeal the decision of the board to the circuit court of the county where the employing district is located, and such appeals "shall be heard as provided in chapter 536, RSMo.”
— Mo. Rev. Stat. § 168.114(2) — 1 case
Humburg v. Bayless Sch. Dist., 7 S.W.3d 553 (Mo. Ct. App. 1999).
— Mo. Rev. Stat. § 168.114(4) — 1 case
Lacks v. Ferguson Reorganized Sch. Dist., R-2, 936 F. Supp. 676 (E.D. Mo. 1996). “Mo.Rev.Stat. § 168.114(1). Terminated teachers can appeal the decision of the board to the circuit court of the county where the employing district is located, and such appeals "shall be heard as provided in chapter 536, RSMo.”
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