Missouri Revised Statutes

Mo. Rev. Stat. § 508.030 (2026)

Actions for real estate, where commenced

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  508.030.  Actions for real estate, where commenced. — Suits for the possession of real estate, or whereby the title thereto may be affected, or for the enforcement of the lien of any special tax bill thereon, shall be brought in the county where such real estate, or some part thereof, is situated.

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(RSMo 1939 § 873)

Prior revisions: 1929 § 722; 1919 § 1179; 1909 § 1753

(1975) In either, a suit for specific performance or a suit on a contract incidentally requiring a delivery of a deed, concerning land in Camden County, venue is in Camden County and Jackson County circuit court was without jurisdiction. State ex rel. Uskali v. Snodgrass (A.), 524 S.W.2d 888.

(1977) Venue for actions which affect title to real estate cannot be waived. Gorman v. State Highway Commission (A.), 552 S.W.2d 335.

Notes of Decisions
Cited in 34 cases (1 in the last 5 years), 1952–2021 · leading case: HFC Investments, LLC v. Valley View State Bank, 361 S.W.3d 450 (Mo. Ct. App. 2012).
HFC Investments, LLC v. Valley View State Bank, 361 S.W.3d 450 (Mo. Ct. App. 2012). · cites it 27× “1967) (“The joining of the action to set aside the fraudulent conveyance [of real estate] with the [non-real estate related] action for accounting and partnership dissolution does not permit the plaintiff to avoid the mandatory effect of § 508.”
Lochhaas v. Burnett, 77 S.W.3d 12 (Mo. Ct. App. 2002). · cites it 11× “The court considered section 508.030 RSMo 1969, which stated that “[sjuits for the possession of real estate, or whereby title thereto may be affected, .”
Sabatino v. Lasalle Bank, N.A., 96 S.W.3d 113 (Mo. Ct. App. 2003). · cites it 12× “030 RSMo (2000) applies; therefore, any action on the deed of trust can be properly brought only in Platte County; (2) Kathryn Sabatino is not a party to any of the forum selection clauses; and (3) as the portion of the lawsuit involving the deed of trust must be brought in…”
Skatoff v. Alfend, 411 S.W.2d 169 (Mo. 1966). · cites it 14× “Relying on Section 508.030, RSMo 1959, V.A. M.S., which provides that `Suits * * * whereby the title thereto (to real estate) may be affected, * * * shall be brought in the county where such real estate, or some part thereof, is situated' the court entered an order and judgment…”
State ex rel. Clayton Greens Nursing Ctr., Inc. v. Marsh, 634 S.W.2d 462 (Mo. 1982). · cites it 6× “See, Section 508.030, RSMo 1978. The question then is whether filing of the lien action in St.”
Gorman v. State High. Comm'n, 552 S.W.2d 335 (Mo. Ct. App. 1977). · cites it 5× “It is the express provision of § 508.030, RSMo 1969, that: Suits for the possession of real estate, or whereby the title thereto may be affected, .”
Sisk v. Molinaro, 376 S.W.2d 175 (Mo. 1964). · cites it 8× “, provides that such a defense is not waived by a failure to plead it, and it is very generally considered that the defense of jurisdiction over the subject matter may not be waived.”
State ex rel. State High. Comm'n v. Swink, 537 S.W.2d 556 (Mo. 1976). · cites it 4× “A case advanced by the relator to establish that section 508.030 has been held not to control in inverse condemnation actions against the state is similarly *561 unconvincing.”
Howell v. Reynolds, 249 S.W.2d 381 (Mo. 1952). · cites it 5× “Louis County? And, if it did not, then does this court have jurisdiction of the appeal? Section 508.030 RSMo 1949, V.A.M.S., provides: "Suits for the possession of real estate, or whereby the title thereto may be affected * * * shall be brought in the county where such real…”
Mercantile Trust Co. Nat'l Ass'n v. Anderson, 611 S.W.2d 548 (Mo. Ct. App. 1981). · cites it 6× “He argues that the primary object of the suit is a transfer of Jefferson County real estate, and as such, is a suit whereby title to real estate may be affected, and is therefore local to Jefferson County under § 508.030 RSMo 1978. 1 Relator, on the other hand, characterizes the…”
State ex rel. Dowd v. Turpin, 576 S.W.2d 754 (Mo. Ct. App. 1979). · cites it 5× “The question for determination is whether or not plaintiffs’ petition is an action for possession of real estate within the meaning of § 508.030, RSMo. whereby venue would be in Pike County.”
Hughes v. Spence, 409 S.W.2d 701 (Mo. 1966). · cites it 10× “Although Doctor Spence invoked the jurisdiction of the Pemiscot County Circuit Court below, appellants now suggest that the action there was one affecting title to real estate within § 508.030, RSMo 1959, V.A.M.S., and that, since the real estate involved is situated in Dunklin…”
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