Mo. Rev. Stat. » Chapter 287
Missouri Revised Statutes

Mo. Rev. Stat. § 287.270 (2026)

Benefits from other sources no bar to compensation, exception, professional athletes

✓ current as of May 2026
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  287.270.  Benefits from other sources no bar to compensation, exception, professional athletes. — No savings or insurance of the injured employee, nor any benefits derived from any other source than the employer or the employer's insurer for liability under this chapter, shall be considered in determining the compensation due hereunder; except as provided in subsection 3* of section 287.170, and employers of professional athletes under contract shall be entitled to full credit for wages or benefits paid to the employee after the injury including medical, surgical or hospital benefits paid to or for the employee or his dependents on account of the injury, disability, or death, pursuant to the provisions of the contract.

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(RSMo 1939 § 3712, A.L. 1984 H.B. 1106, A.L. 1998 H.B. 1237, et al.)

Prior revision: 1929 § 3322

*Subsection 3 of section 283.170 was removed by S.B. 1 & 130, 2005.  This language no longer exists.

Notes of Decisions
Cited in 32 cases, 1956–2016 · leading case: Dubinsky v. St. Louis Blues Hockey Club, 229 S.W.3d 126 (Mo. Ct. App. 2007).
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Dubinsky v. St. Louis Blues Hockey Club, 229 S.W.3d 126 (Mo. Ct. App. 2007). · cites it 28× “Louis Blues Hockey Club (“Employer”) a credit in that same amount pursuant to section 287.270 RSMo 2000. 1 Finding no error, we affirm.”
Porter v. Toys 'R' US-Delaware, Inc., 152 S.W.3d 310 (Mo. Ct. App. 2004). · cites it 11× “She claimed that section 287.270, RSMo 2000, which provides that in workers’ compensation cases an employer’s liability is not reduced by the amount of contributions to the employee from another source, mandates that such reductions of her medical expenses should not be…”
Phillips v. Par Elec. Contractors, 92 S.W.3d 278 (Mo. Ct. App. 2002). · cites it 14× “The Commission had the following to say about Wilmeth and how it applied to the facts of this case: The court, relying on § 287.270 RSMo, rejected the Fund’s [similar] argument in Wilmeth because the benefits paid by the employer’s accidental insurance company were not paid…”
Maness v. City of De Soto, 421 S.W.3d 532 (Mo. Ct. App. 2014). · cites it 8× “” Mo. Rev.Stat. § 287.270. “This section clearly was intended to allow the employee to benefit from any collateral source the employee might have available to him or her, independent of the employer, whether purchased or not.”
Wilmeth v. TMI, INC., 26 S.W.3d 476 (Mo. Ct. App. 2000). · cites it 13× “Point II of TMI’s appeal and the Second Injury Fund’s Point III claim § 287.270, RSMo Cum.Supp.1999, entitled them to credit for amounts paid by Monumental Life.”
Ellis v. Missouri State Treasurer, 302 S.W.3d 217 (Mo. Ct. App. 2009). · cites it 10× “Although the SIF believes the resolution of this appeal will require us to determine whether the Commission misapplied the law when it ruled that section 287.270 1 prevents the SIF from reducing its liability based on payments or write-offs made by entities other than Claimant’s…”
Farmer-Cummings v. Pers. Pool of Platte Cnty., 110 S.W.3d 818 (Mo. 2003). · cites it 8× “Farmer-Cummings claims, however, that section 287.270 mandates that any such reductions not be considered, and accordingly, that her recovery not be diminished by them.”
Cook v. Sunnen Prods. Corp., 937 S.W.2d 221 (Mo. Ct. App. 1996). · cites it 11× “§ 287.270, RSMo. Furthermore, the statutes also explain when an employer is entitled to a credit for wages paid: “The employer shall not be entitled to credit for wages or such pay benefits paid to the employee or his dependents on account of the injury or death except as…”
Lisa Cook, Claimant-respondent v. Missouri High. & Transp. Comm'n, Emp.-appellant., 500 S.W.3d 917 (Mo. Ct. App. 2016). · cites it 6× “banc 2003) (such as employee’s liability for the medical expenses was extinguished, or that liability does not otherwise fall within other statutory provisions); § 287.270 (allowing an employer to receive a credit for medical bills paid by the employer).”
Mann v. Varney Constr., 23 S.W.3d 231 (Mo. Ct. App. 2000). · cites it 6× “Claimant further argues Section 287.270 mandates payment of the full amount of medical bills by the employer regardless of a payment by a collateral source not funded exclusively by the employer even where this results in a windfall to the employee.”
Strohmeyer v. Sw. Bell Tel. Co., 396 S.W.2d 1 (Mo. Ct. App. 1965). · cites it 6× “The second allegation of -error is that the trial court and the commission misconstrued the provisions of § 287.270, RSMo 1959, V.A.M.S., which he contends bars this credit.”
Campbell v. Citicorp Mortg., Inc., 924 S.W.2d 323 (Mo. Ct. App. 1996). · cites it 10× “Citi- *324 eorp argues: 1) sick-leave payments made to Claimant satisfy the requirements of § 287.270 RSMo 1986; and, 2) the Commission had no jurisdiction to order reinstatement of sick leave benefits.”
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