Mo. Rev. Stat. » Chapter 435
Missouri Revised Statutes

Mo. Rev. Stat. § 435.410 (2026)

Modification or correction of award

✓ current as of May 2026
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  435.410.  Modification or correction of award. — 1.  Upon application made within ninety days after delivery of a copy of the award to the applicant, the court shall modify or correct the award where:

  (1)  There was an evident miscalculation of figures or an evident mistake in the description of any person, thing or property referred to in the award;

  (2)  The arbitrators have awarded upon a matter not submitted to them and the award may be corrected without affecting the merits of the decision upon the issues submitted; or

  (3)  The award is imperfect in a matter of form, not affecting the merits of the controversy.

  2.  If the application is granted, the court shall modify and correct the award so as to effect its intent and shall confirm the award as so modified and corrected.  Otherwise, the court shall confirm the award as made.

  3.  An application to modify or correct an award may be joined in the alternative with an application to vacate the award.

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(L. 1980 H.B. 1203 § 13)

Notes of Decisions
Cited in 13 cases, 1990–2020 · leading case: Nat'l Avenue Bldg. Co. v. Stewart, 910 S.W.2d 334 (Mo. Ct. App. 1995).
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Nat'l Avenue Bldg. Co. v. Stewart, 910 S.W.2d 334 (Mo. Ct. App. 1995). · cites it 3× “2 The other statute invoked by Pleading A is § 435.410, which governs modification or correction of an arbitration award.”
Decker v. Kamil, 100 S.W.3d 115 (Mo. Ct. App. 2003). · cites it 6× “Appellant claims in the sole point relied on that the trial court erred in failing to modify the award pursuant to Section 435.410(1). Kamil claims he made a $25,000.”
State Ex Rel. Stewart v. McGuire, 838 S.W.2d 516 (Mo. Ct. App. 1992). · cites it 3× “The statute pertaining to modification is § 435.410. Grounds for modification are set forth in subsection 1 of that statute.”
Nat'l Avenue Bldg. Co. v. Stewart, 794 S.W.2d 304 (Mo. Ct. App. 1990). · cites it 3× “405, or in the alternative to modify the award per § 435.410. This motion alleged, among other things, that some of Stewart’s exhib *306 its in the arbitration proceeding were not made available to National in advance, that the arbitrators’ award indicated a manifest disregard…”
R.L. Hulett & Co. v. Barth, 884 S.W.2d 309 (Mo. Ct. App. 1994). · cites it 2× “405 and § 435.410, RSMo 1986, for vacating, modifying, or correcting the award.”
Maxwell-Gabel Contracting Co. v. City of Milan, 147 S.W.3d 93 (Mo. Ct. App. 2004). · cites it 3× “The City filed its motion to modify and correct the arbitration award in accordance with section 435.410, RSMo 2000, claiming that the arbitrators “improperly awarded pre-award interest” and seeking declaration of the City’s duty to withhold funds by statute.”
Nat'l Avenue Bldg. Co. v. Stewart, 838 S.W.2d 514 (Mo. Ct. App. 1992). “405, 1 or in the alternative to modify it per § 435.410. See: 794 S.W.2d at 305-06 . The award (by a three-member panel appointed by the American Arbitration Association) had been filed in the trial court February 2,1988, by Donald R.”
Birchtree Fin. Servs., Inc. v. Thomas, 821 S.W.2d 120 (Mo. Ct. App. 1991). · cites it 2× “” Section 435.410 also supplies a ninety day time limit for modifying or correcting an award.”
Nat'l Avenue Bldg. Co. v. Stewart, 972 S.W.2d 649 (Mo. Ct. App. 1998). “17, an amount that did not include interest at the rate of 10% from the date of the arbitration award to the date of judgment, in that [Stewart] was entitled to interest on the amount awarded as damages by the arbitration panel for the reason that the contract between [Stewart]…”
Cacheris v. Mayer Homes, Inc., 969 S.W.2d 876 (Mo. Ct. App. 1998). · cites it 4× “Section 435.410 authorizes a trial court to correct or modify an award where: (1) There was an evident miscalculation of figures or an evident mistake in the description of any person, thing or property referred to in the award; (2) The arbitrators have awarded upon a matter not…”
In Re the Arbitration of: Charles Scott Earls & Lisa Marie Earls v. Northpointe Dev. Co., LLC, Respondent-respondent., 486 S.W.3d 363 (Mo. Ct. App. 2015). · cites it 3× “Presenting two points on appeal, the Earls contend the trial court erred by registering the judgment with the limiting language because: (1) the arbitration award did not contain the limitation, and Northpointe did not file a motion to modify the award as required by § 435.410;…”
Asset Acceptance LLC v. Schaumann, 332 S.W.3d 196 (Mo. Ct. App. 2010). · cites it 2× “2; see also Section 435.410 (imposing a ninety-day limit for application to modify or correct an arbitration award).”
Show all 13 citing cases →
— Mo. Rev. Stat. § 435.410(1) — 1 case
Decker v. Kamil, 100 S.W.3d 115 (Mo. Ct. App. 2003). “Appellant claims in the sole point relied on that the trial court erred in failing to modify the award pursuant to Section 435.410(1). Kamil claims he made a $25,000.”
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