Missouri Revised Statutes

Mo. Rev. Stat. § 484.010 (2026)

Practice of the law and law business defined

✓ current as of May 2026

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484.010. Practice of the law and law business defined. — 1. The "practice of the law" is hereby defined to be and is the appearance as an advocate in a representative capacity or the drawing of papers, pleadings or documents or the performance of any act in such capacity in connection with proceedings pending or prospective before any court of record, commissioner, referee or any body, board, committee or commission constituted by law or having authority to settle controversies.

2. The "law business" is hereby defined to be and is the advising or counseling for a valuable consideration of any person, firm, association, or corporation as to any secular law or the drawing or the procuring of or assisting in the drawing for a valuable consideration of any paper, document or instrument affecting or relating to secular rights or the doing of any act for a valuable consideration in a representative capacity, obtaining or tending to obtain or securing or tending to secure for any person, firm, association or corporation any property or property rights whatsoever.

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(RSMo 1939 § 13313)

Prior revisions: 1929 § 11692; 1919 § 666

(1952) The preparing of real estate contracts, deeds, notes, leases, chattel mortgages on standardized forms as part of transaction effectuated by real estate broker, does not amount to practice of law; but the preparation of such instruments in transactions in which he is not acting as broker or the making of separate charges for such services even when he acts as broker, or the giving of legal advice, constitutes practice of law and is in contempt of court if done by nonlawyer. Hulse v. Criger, 363 Mo. 26, 247 S.W.2d 855.

(1960) The definition in this statute of the practice of law is binding on the court in a proceeding under § 484.020 which makes violation of the statute a misdemeanor but it is not binding in a proceeding to enjoin the practice of law by an individual for the reason the power to regulate and define the practice of law and the doing of law business is a prerogative of the judicial department. Automobile Club of Mo. v. Hoffmeister (A.), 338 S.W.2d 348.

(1960) The appearance by Automobile Club attorneys in court to enter pleas of guilty and pay fine for members of the club and to obtain continuances of cases held to constitute the practice of law and therefore subject to being enjoined. Automobile Club of Mo. v. Hoffmeister (A.), 338 S.W.2d 348.

(1960) The representation of himself by a party to a law suit does not constitute the practice of law. Klingensmith v. Thurman (A.), 339 S.W.2d 300.

(1961) Individual layman employed as the community services representative of labor council, who advised various individuals as to their rights under the workmen's compensation law after they were injured and also appeared before the legal advisers of the workmen's compensation division as well as representing individuals who were seeking unemployment compensation benefits before referees of the division of employment security, was engaged in the practice of law for a consideration and would be enjoined by the supreme court and also fined for engaging in such practice without being a duly licensed attorney. Hoffmeister v. Tod (Mo.), 349 S.W.2d 5.

(1978) Held, advertisement and sale of "divorce kits" does not constitute the unauthorized practice of law so long as no personal advice as to legal remedies is given. In re Thompson (Mo.), 574 S.W.2d 365.

(1992) Escrow companies may not prepare or complete nonstandard or specialized documents such as contracts for deed, special warranty deeds, leases, lease-purchase agreements, easement agreements, well agreements, trustee deeds, wraparound notes and deeds of trust or any other document that requires the exercise of judgment or discretion, because such activities constitute the practice of law or doing business of law in the state, In re First Escrow, Inc., 840 S.W.2d 839 (Mo. banc).

Notes of Decisions

Cited in 39 cases (3 in the last 5 years), 1960–2025 · leading case: In Re Allstate Ins. Co., 722 S.W.2d 947 (Mo. 1987).

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In Re Allstate Ins. Co., 722 S.W.2d 947 (Mo. 1987). · cites it 30× “1, it has no legal authority to do so. Violation of the statute has been declared to be a crime.”

Carpenter v. Countrywide Home Loans, Inc., 250 S.W.3d 697 (Mo. 2008). · cites it 9× “The plaintiffs alleged that this activity constituted the unauthorized practice of law business prohibited by section 484.010 et seq. because the documents were not prepared by lawyers.”

Bray v. Brooks, 41 S.W.3d 7 (Mo. Ct. App. 2001). · cites it 13× “Although we find that Bray engaged in the unauthorized practice of law as defined in § 484.010, we also find there was insufficient evidence to support an award of treble damages for that violation.”

Reed v. Labor & Indus. Relations Comm'n, 789 S.W.2d 19 (Mo. 1990). · cites it 10× “NOTES [1] Section 484.010, RSMo 1986 reads: 1. The "practice of the law" is hereby defined to be and is the appearance as an advocate in a representative capacity or the drawing of papers, pleadings or documents or the performance of any act in such capacity in connection with…”

Eisel v. Midwest BankCentre, 230 S.W.3d 335 (Mo. 2007). · cites it 5× “The document preparation fees at issue violate a plain reading of sections 484.010 and 484.020. Under the facts of this case, the statutes are not inconsistent with this Court’s cases defining the practice of law.”

Haggard v. Div. of Emp. Sec., 238 S.W.3d 151 (Mo. 2007). · cites it 6× “banc 1990); see section 484.010. 3 This Court has said: One is engaged in the practice of law when he, for a valuable consideration appears in a representative capacity as an advocate in proceedings pending or prospective, before any court, commissioner, referee, board, body,…”

Hargis v. JLB Corp., 357 S.W.3d 574 (Mo. 2011). · cites it 3× “Count I alleges that JLB engaged in the unauthorized practice of law in violation of section 484.010 3 in charging her a fee for preparing, procuring and assisting in the drawing of legal documents and in preparing her loan application and other financial disclosures as it…”

Robert McKeage v. TMBC, LLC, 847 F.3d 992 (8th Cir. 2017). · cites it 2× “After approving class certification, the district court determined that TMBC prepared legal documents attendant to its sales and that charging a fee for those documents constituted unauthorized law business in violation of Mo. Rev. Stat. §§ 484.010 and 484.020. The district…”

Sch. Dist. of Kansas City v. Missouri Bd. of Fund Commissioners, 384 S.W.3d 238 (Mo. Ct. App. 2012). · cites it 4× “banc 2007), recognize a narrow exception to the voluntary payment doctrine for violations of section 484.010 et seq. (describing the unauthorized practice of law), and hold that claims under that statute are “ ‘not subject to waiver, consent or lack of objection by the victim.”

Lucas Subway MidMo, Inc. v. Mandatory Poster Agency, Inc., 524 S.W.3d 116 (Mo. Ct. App. 2017). · cites it 8× “MPA argues that the corporate minutes are merely form documents and more akin to a document with legal effect rather than a legal document as contemplated by section 484.010. MPA characterizes its services as merely taking a form filled out by customers and entering the data…”

In Re First Escrow, Inc., 840 S.W.2d 839 (Mo. 1992). · cites it 4× “The Hulse /Section 484.010 definition of the law business focuses on the "drawing" of legal documents.”

Janson v. Legalzoom.Com, Inc., 271 F.R.D. 506 (W.D. Mo. 2010). · cites it 8× “the drawing or the procuring of or assisting in the drawing for a valuable consideration of any paper, document or instrument affecting or relating to secular rights____ § 484.010 RSMo. Meanwhile, the Missouri MPA provides: The act, use or employment by any person of any…”

Show all 39 citing cases →

— Mo. Rev. Stat. § 484.010(1) — 2 cases

In Re Allstate Ins. Co., 722 S.W.2d 947 (Mo. 1987). “1, it has no legal authority to do so. Violation of the statute has been declared to be a crime.”

Stewart v. Stewart, 693 S.W.2d 305 (Mo. Ct. App. 1985).

— Mo. Rev. Stat. § 484.010(2) — 1 case

In Re Allstate Ins. Co., 722 S.W.2d 947 (Mo. 1987). “1, it has no legal authority to do so. Violation of the statute has been declared to be a crime.”

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