Missouri Revised Statutes

Mo. Rev. Stat. § 178.900 (2026)

Definitions

✓ current as of May 2026

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178.900. Definitions. — For the purposes of sections 178.900 to 178.960 the following words mean:

(1) "Department", the department of elementary and secondary education;

(2) "Disabled persons", a lower range educable or upper range trainable developmentally disabled or other disabled person sixteen years of age or over who has had school training and has a productive work capacity in a sheltered environment adapted to the abilities of persons with a developmental disability but whose limited capabilities make him or her nonemployable in competitive business and industry and unsuited for vocational rehabilitation training;

(3) "Sheltered workshop", an occupation-oriented facility operated by a not-for-profit corporation, which, except for its staff, employs only persons with disabilities and has a minimum enrollment of at least fifteen employable persons with disabilities;

(4) "Staff", employees of a sheltered workshop engaged in management, work procurement, purchasing, supervision, sales, bookkeeping, and secretarial and clerical functions.

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(L. 1965 p. 309 § 1, A.L. 2011 H.B. 555 merged with H.B. 648)

CROSS REFERENCE:

Transportation for sheltered workshop employees and residents of facilities or social center for the disabled, 162.755

Notes of Decisions

Cited in 7 cases, 1980–2020 · leading case: Vocational Servs., Inc. v. Developmental Disabilities Resource Bd., 5 S.W.3d 625 (Mo. Ct. App. 1999).

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Vocational Servs., Inc. v. Developmental Disabilities Resource Bd., 5 S.W.3d 625 (Mo. Ct. App. 1999). · cites it 9× “968 was further amended to state, “The board of directors shall be a legal entity empowered to establish and/or operate a sheltered workshop as defined in section 178.900, RSMo, residence facilities, or related services, for the care or employment, or both, of handicapped…”

Welsch v. Dept. of Elementary & Secondary Educ., 731 S.W.2d 450 (Mo. Ct. App. 1987). · cites it 6× “” The appellant, charged with administering the sheltered workshop statutes, §§ 178.900, et seq., RSMo 1978 promulgated rules regulating the agencies which operate sheltered workshops, 5 CSR 70-770.”

Proj., Inc. v. Productive Living Bd. for St. Louis Cnty. Citizens With Developmental Disabilities, 234 S.W.3d 597 (Mo. Ct. App. 2007). · cites it 6× “For purposes of gaining employment at a sheltered workshop, a "handicapped person" is defined by Section 178.900(2) RSMo (2000) as "a lower range educable or upper range trainable mentally retarded or other handicapped person sixteen years of age or over who has had school…”

Tri-Cnty. Counseling Servs., Inc v. Off. of Admin. (Mo. Ct. App. 2020). · cites it 5× “10 Lake Area Industries was a general not-for-profit Missouri corporation certified to operate a sheltered workshop by the Department of Elementary and Secondary Education pursuant to section 178.900 et seq. Prior to its interactions with Family Facets, Lake Area Industries had…”

Joplin Workshops, Inc. v. Jasper Cnty. Sheltered Facilities Bd., 308 S.W.3d 252 (Mo. Ct. App. 2010). · cites it 2× “The uncontroverted material facts before the trial court in deciding this motion were: Workshop is a sheltered workshop as defined by section 178.900; Board is a political subdivision; on November 2, 1976, the voters of Jasper County approved the question, “Shall Jasper County…”

State ex inf. Ashcroft ex rel. St. Louis Cnty. v. O'Brien, 610 S.W.2d 638 (Mo. Ct. App. 1980). “authorizing any county in the state to establish sheltered workshops to be operated for handicapped persons as defined in § 178.900. In accordance with the power granted by the legislature the qualified voters of St.”

Thomas Dubuc v. Treasurer of the State of Missouri-Custodian of the Second Injury Fund (Mo. Ct. App. 2020). “972 or sections 178.900 to 178.960 and such employee thereafter sustains a compensable work-related injury that, when combined with the preexisting disability, results in permanent total disability as defined under this chapter.”

— Mo. Rev. Stat. § 178.900(2) — 2 cases

Proj., Inc. v. Productive Living Bd. for St. Louis Cnty. Citizens With Developmental Disabilities, 234 S.W.3d 597 (Mo. Ct. App. 2007). “For purposes of gaining employment at a sheltered workshop, a "handicapped person" is defined by Section 178.900(2) RSMo (2000) as "a lower range educable or upper range trainable mentally retarded or other handicapped person sixteen years of age or over who has had school…”

Welsch v. Dept. of Elementary & Secondary Educ., 731 S.W.2d 450 (Mo. Ct. App. 1987). “” The appellant, charged with administering the sheltered workshop statutes, §§ 178.900, et seq., RSMo 1978 promulgated rules regulating the agencies which operate sheltered workshops, 5 CSR 70-770.”

— Mo. Rev. Stat. § 178.900(3) — 3 cases

Tri-Cnty. Counseling Servs., Inc v. Off. of Admin. (Mo. Ct. App. 2020). “10 Lake Area Industries was a general not-for-profit Missouri corporation certified to operate a sheltered workshop by the Department of Elementary and Secondary Education pursuant to section 178.900 et seq. Prior to its interactions with Family Facets, Lake Area Industries had…”

— Mo. Rev. Stat. § 178.900(4) — 1 case

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