Missouri Revised Statutes

Mo. Rev. Stat. § 327.461 (2026)

Contract with unlicensed architect, professional engineer, professional land surveyor, or professional landscape architect unenforceable by them

✓ current as of May 2026
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  327.461.  Contract with unlicensed architect, professional engineer, professional land surveyor, or professional landscape architect unenforceable by them. — Every contract for architectural or engineering or land surveying or landscape architectural services entered into by any person who is not an architect or professional engineer or professional land surveyor or professional landscape architect, as the case may be, and who is not exempt from the provisions of this chapter, shall be unenforceable by the unlicensed or unauthorized person, whether in contract, quantum meruit or other legal theory, regardless of whether a benefit has been conferred.

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(L. 1969 S.B. 117, A.L. 1999 H.B. 343, A.L. 2014 S.B. 809)

Notes of Decisions
Cited in 13 cases, 1976–2017 · leading case: Far East Servs. Corp. v. Tracker Marine, L.L.C., 246 S.W.3d 486 (Mo. Ct. App. 2007).
Far East Servs. Corp. v. Tracker Marine, L.L.C., 246 S.W.3d 486 (Mo. Ct. App. 2007). · cites it 25× “Tracker’s eight points challenge four areas of the judgment: points eight, nine, ten, and eleven contest the award of damages in favor of Far East for the contract price of the July parts; point thirteen challenges the trial court’s award of pre-judgment interest on such award;…”
Hosp. Dev. Corp. v. Park Lane Land Co., 813 S.W.2d 904 (Mo. Ct. App. 1991). · cites it 13× “Section 327.461 RSMo 1986 provides: Every contract for architectural or engineering or land surveying services entered into by any person who is not a registered or authorized architect or registered or authorized professional engineer or registered or authorized land surveyor,…”
Haith & Co. v. Ellers, Oakley, Chester & Rike, Inc., 778 S.W.2d 417 (Mo. Ct. App. 1989). · cites it 9× “Furthermore, the legislature specifically provided in § 327.461 that: [e]very contract for ... engineering .”
Charles C. MacLean, III, Architect, Ltd. v. Ozark Mountain Country Mall, Inc. (In Re Branson Mall, Inc.), 120 B.R. 1006 (Bankr. W.D. Mo. 1990). · cites it 16× “015, and is also precluded from enforcing said contract pursuant to Mo.Rev. Stat. § 327.461. Plaintiff responded by arguing that summary judgment was not appropriate because a genuine issue of material fact existed as to when the written contract was executed.”
Cornelius v. CJ MORRILL, 302 S.W.3d 176 (Mo. Ct. App. 2009). · cites it 8× “405, including that defendant, who was not a Missouri licensed architect, could not enforce the contract containing the arbitration provisions because it included architectural services which, under section 327.461, could not be enforced by an unlicensed person.”
Kansas City Power & Light Co. v. Bibb & Assocs., Inc., 197 S.W.3d 147 (Mo. Ct. App. 2006). · cites it 2× “In point III, KCPL alleges that Rockwell could not enforce the contractual limitation of liability provision because (1) it was not a third party beneficiary of the For-ney/KCPL contract and was not Forney’s vendor, (2) under section 327.461, Forney was not authorized to perform…”
Anglin Eng'g Co. v. BARRY CO., INC., 912 S.W.2d 633 (Mo. Ct. App. 1995). · cites it 5× “It argues the contract with Anglin was unenforceable under § 327.461, RSMo (1994), because Anglin was providing engineering services without being a registered or authorized professional engineer.”
Space Planners Architects, Inc. v. Frontier Town-Missouri, Inc., 107 S.W.3d 398 (Mo. Ct. App. 2003). · cites it 2× “§ 327.461; 8 Hosp. Dev. Corp. v. Park Lane Land, 813 S.”
Maran-Cooke, Inc. v. Purler Excavating, Inc., 585 S.W.2d 38 (Mo. 1979). · cites it 2× “Respondents relied below on § 327.461: “Every contract for . . engineering .”
Bank of Houston v. Action Land & Cattle Co., 521 S.W.3d 304 (Mo. Ct. App. 2017). “, § 327.461 (providing that a contract by an unlicensed architect or'engineer “shall be unenforceable”); § 390.”
Carson-Mitchell, Inc. v. Macon Beef Packers, Inc., 544 S.W.2d 275 (Mo. Ct. App. 1976). “260 and § 327.461 were applicable to the instant action.”
Strain-Japan R-16 Sch. Dist. v. Landmark Sys., Inc., 965 S.W.2d 278 (Mo. Ct. App. 1998). · cites it 9× “The appellant school district sued for an injunction against arbitration proceedings sought by the defendant contractor, asserting that the contractor had violated section 327.461 RSMo.1994 by entering into a contract to render professional engineering services without being…”
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