Missouri Revised Statutes

Mo. Rev. Stat. § 375.934 (2026)

Unfair trade practices

✓ current as of May 2026
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  375.934.  Unfair trade practices — conditions. — It is an unfair trade practice for any insurer to commit any practice defined in section 375.936 if:

  (1)  It is committed in conscious disregard of sections 375.930 to 375.948 or of any rules promulgated under sections 375.930 to 375.948; or

  (2)  It has been committed with such frequency to indicate a general business practice to engage in that type of conduct.

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(L. 1959 H.B. 251 § 3, A.L. 1978 H.B. 1447, A.L. 1991 S.B. 53)

Notes of Decisions
Cited in 7 cases, 1985–1999 · leading case: Dierkes v. Blue Cross & Blue Shield of Missouri, 991 S.W.2d 662 (Mo. 1999).
Dierkes v. Blue Cross & Blue Shield of Missouri, 991 S.W.2d 662 (Mo. 1999). · cites it 5× “In the same way, section 375.934 prohibits unfair trade practices, including false advertising and misrepresentation for the benefit of the general insurance purchasing public.”
Farm Bureau Town & Country Ins. Co. v. Angoff, 909 S.W.2d 348 (Mo. 1995). · cites it 2× “Section 375.934 provides: It is an unfair trade practice for any insurer to commit any practice defined in section 375.”
Prof'l Ins. Managers, Inc. v. RCA Mut. Ins. Co., 884 S.W.2d 332 (Mo. Ct. App. 1994). · cites it 7× “Appellants’ complaint in their first point relates to the Director’s finding that RCA’s statements in its letters were not untrue, deceptive or misleading and that it did not, therefore, engage in unfair trade practices prohibited by §§ 375.934 and .936. Appellants rely on § 375.”
Klinginsmith v. Missouri Dep't of Consum. Affairs, 693 S.W.2d 226 (Mo. Ct. App. 1985). · cites it 2× “As additional relief, the petition sought a declaration that respondent Missouri Department of Consumer Affairs, Regulation and Licensing, Division of Insurance has a duty to apply anti-discrimination statutes, § 375.934 and § 375.936, to health services corporations and to…”
Davis v. Dir. of Ins., 879 S.W.2d 556 (Mo. Ct. App. 1994). · cites it 2× “Furthermore, § 375.934 applies to insurers, not to adjusters.”
Risk Control Assocs., Inc. v. Melahn, 822 S.W.2d 531 (Mo. Ct. App. 1991). · cites it 3× “The complaint also alleged that RCA had engaged in an unfair trade practice in violation of § 375.934, RSMo 1986, 3 in the circulation of the letter.”
McKee Baking Co. v. Interstate Brands Corp., 738 F. Supp. 1272 (E.D. Mo. 1990). “§ 375.934 and Missouri common law, seeking injunctive, declaratory and monetary relief.”
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