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Missouri Revised Statutes

Mo. Rev. Stat. § 441.160 (2026)

Executor or administrator of tenant for life may recover rents

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  441.160.  Executor or administrator of tenant for life may recover rents. — The executors or administrators of any tenant for life, who shall have demised any lands or tenements so held, and shall die on or before the day when any rent on such demise shall become payable, may recover:

  (1)  If such tenant for life die on the day, the whole rent;

  (2)  If he die before the day, such proportion of the rent as shall have accrued before his death.

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(RSMo 1939 § 2959)

Prior revisions: 1929 § 2573; 1919 § 6869; 1909 § 7871

CROSS REFERENCE:

Unlawful detainer action, cause survives on death of lessor, 534.270

(1959) Where life tenant leased farm to tenant for crop rent and died after the crop was planted but before maturity or harvest, the rent did not accrue during life estate so that remaindermen were entitled to the proceeds from sale of crop.  In re North's Estate (A.), 320 S.W.2d 597.

Notes of Decisions
Cited in 4 cases, 1959–1995 · leading case: In re North's Est., 320 S.W.2d 597 (Mo. Ct. App. 1959).
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In re North's Est., 320 S.W.2d 597 (Mo. Ct. App. 1959). · cites it 4× “reads: "The executors or administrators of any tenant for life, who shall have demised any lands or tenements so held, and shall die on or before the day when any rent on such demise shall become payable, may recover (1) If such tenant for life die on the day, the whole rent;…”
Parkville Benefit Assessment Spec. Road Dist. v. Platte Cnty., 906 S.W.2d 766 (Mo. Ct. App. 1995). “” Appellant’s reliance on this definition as the plain meaning of “accrue” is misplaced, as In re Estate of North dealt specifically with the interpretation of its meaning within RSMo § 441.160. *770 A more persuasive argument for the plain meaning of the term “accrue” is found…”
Alewel v. Vollmer, 485 S.W.2d 682 (Mo. Ct. App. 1972). “Appellants rely on §§ 441.160 and 441.170. These sections are inapplicable since they simply provide that the executor of Frank (the life tenant) is entitled to collect the amount of rent on the property due on Frank’s death.”
York v. Jackson, 320 S.W.2d 597 (Mo. Ct. App. 1959). · cites it 4× “reads: “The executors or administrators of any tenant for life, who shall have demised any lands or tenements so held, and shall die on or before the day when any rent on such demise shall become payable, may recover (1) If such tenant for life die on the day, the whole rent;…”
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