Missouri Revised Statutes

Mo. Rev. Stat. § 435.400 (2026)

Confirmation of an award

✓ current as of May 2026
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  435.400.  Confirmation of an award. — Upon application of a party, the court shall confirm an award, unless within the time limits hereinafter imposed grounds are urged for vacating or modifying or correcting the award, in which case the court shall proceed as provided in sections 435.405 and 435.410.

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(L. 1980 H.B. 1203 § 11)

(1991)  Where employee's suit was a hybrid Section 301 of the federal Labor Management Relations Act and a fair representation claim to which a six-month statute of limitations applied, Missouri statute allowing successful litigant ten years to collect judgment did not apply to employee's suit against his employer to enforce arbitration back pay award.  Livingstone v. Schnuck Market, Inc., 950 F.2d 579 (8th Cir.).

Notes of Decisions
Cited in 34 cases (5 in the last 5 years), 1989–2023 · leading case: Parks v. MBNA Am. Bank, 204 S.W.3d 305 (Mo. Ct. App. 2006).
Parks v. MBNA Am. Bank, 204 S.W.3d 305 (Mo. Ct. App. 2006). · cites it 5× “A motion to confirm an arbitration award is governed substantively by section 9 of the Federal Arbitration Act (FAA) 2 and procedurally by the Missouri Uniform Arbitration Act (MUAA), sections 435.400 and 435.425. 3 Edward D.”
Nat'l Avenue Bldg. Co. v. Stewart, 910 S.W.2d 334 (Mo. Ct. App. 1995). · cites it 6× “2d at 517 — invokes § 435.400. 3 The statutes identified in the two preceding paragraphs are components of Missouri’s “Uniform Arbitration Act,” §§ 435.”
State ex rel. Todd Hewitt, Relator v. Honorable Kristine Kerr, Judge, Circuit Court for St. Louis Cnty., Missouri, 461 S.W.3d 798 (Mo. 2015). · cites it 2× “Section 435.400. If the circuit court confirms, modifies, or corrects the award — that is, if it does not vacate the award — “judgment or decree shall be entered.”
Murray v. Missouri High. & Transp. Comm'n, 37 S.W.3d 228 (Mo. 2001). · cites it 2× “095 lacks judicial review, which it says is fatal to section 226.095’s constitutionality.”
Jennifer A. Britt v. Jeremy M. Otto, 577 S.W.3d 133 (Mo. Ct. App. 2019). · cites it 2× “Pursuant to section 435.400, upon application of a party to an arbitration proceeding, "the court shall confirm an award, unless within the time limits hereinafter imposed grounds are urged for vacating or modifying or correcting the award .”
Matthew Alexander Nicholson & Jailyn Marchai Nicholson, Plaintiffs-respondents v. Surrey Vacation Resorts, Inc., 463 S.W.3d 358 (Mo. Ct. App. 2015). · cites it 2× “Section 435.400 has redefined the parameters of appealability in the context of an interlocutory appeal as opposed to an appeal of a final judgment such that Spiece is dissimilar and does not affect this district’s view , of Jackson Cnty.”
Est. of Sandefur v. Greenway, 898 S.W.2d 667 (Mo. Ct. App. 1995). · cites it 3× “In this appeal from a circuit court decision asking to confirm an arbitration award in favor of a customer against her stockbroker, under § 435.400, RSMo 1994 (all further statutory references will be to the Revised Statutes of 1994), there are two issues presented: 1) may the…”
R.L. Hulett & Co. v. Barth, 884 S.W.2d 309 (Mo. Ct. App. 1994). · cites it 2× “See § 435.400, RSMo 1986. Defendants filed a motion to strike the award, alleging it was procured through fraudulently prepared documents and perjured testimony.”
Maxwell-Gabel Contracting Co. v. City of Milan, 147 S.W.3d 93 (Mo. Ct. App. 2004). · cites it 3× “” Maxwell filed its application to confirm the arbitration award in accordance with section 435.400, RSMo 2000. The City filed its motion to modify and correct the arbitration award in accordance with section 435.”
Holman v. Trans World Airlines, Inc., 737 F. Supp. 527 (E.D. Mo. 1989). · cites it 2× “Mo.Rev.Stat. § 435.400. Plaintiff's first contention is that the Board of Adjustment exceeded its powers by failing to give collateral estoppel effect to the decision of the Missouri Division of Employment Security.”
State Ex Rel. Stewart v. McGuire, 838 S.W.2d 516 (Mo. Ct. App. 1992). · cites it 2× “As to Pleading B, § 435.400 reads: Upon application of a party, the court shall confirm an award, unless within the time limits hereinafter imposed grounds are urged for vacating or modifying .”
State ex rel. Telecom Mgmt., Inc. v. O'Mally, 965 S.W.2d 215 (Mo. Ct. App. 1998). · cites it 3× “Section 435.400 requires the courts to confirm arbitration awards unless grounds for vaca-tur under Section 435.”
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