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Missouri Revised Statutes

Mo. Rev. Stat. § 509.200 (2026)

Claims of items of special damage shall be specifically stated

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  509.200.  Claims of items of special damage shall be specifically stated. — When items of special damage are claimed, they shall be specifically stated.  In actions where exemplary or punitive damages are recoverable, the petition shall state separately the amount of such damages sought to be recovered.

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(L. 1943 p. 353 § 52)

Notes of Decisions
Cited in 16 cases (1 in the last 5 years), 1952–2022 · leading case: Green v. Study, 286 S.W.3d 236 (Mo. Ct. App. 2009).
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Green v. Study, 286 S.W.3d 236 (Mo. Ct. App. 2009). · cites it 4× “However, the problem is that under section 509.200 and Rule 55.19 punitive damages must be specifically pled by a party in his or her petition.”
Jaclyn Waters v. Ferrara Candy Co., 873 F.3d 633 (8th Cir. 2017). “See Mo. Rev. Stat. § 509.200 (requiring that petitions explicitly state the amount of punitive damages sought to be recovered).”
Parsons Constr. Co. v. Missouri Pub. Serv. Co., 425 S.W.2d 166 (Mo. 1968). · cites it 3× “” See also, Section 509.200 RSMo 1959, V.A.M.S. General damages are those which the law would impute as the natural, necessary and logical consequence of defendant’s wrongful act.”
Baker v. Atkins, 258 S.W.2d 16 (Mo. Ct. App. 1953). · cites it 3× “Section 509.200, RSMo 1949, V.A.M.S., provides that in actions where exemplary or punitive damages are recoverable, the petition shall state separately the amount of such damages; but there is no statute or rule that requires the claim for punitive damages to be stated in a…”
Duncan v. Townsend, 325 S.W.2d 67 (Mo. Ct. App. 1959). · cites it 3× “Section 509.200 RSMo 1949, V.A.M.S.; Young v.”
Williams v. Kansas City Pub. Serv. Co., 294 S.W.2d 36 (Mo. 1956). · cites it 3× “However, whether we treat count II as purporting to state -a claim separate from that in count I as Section 509.”
Contestible v. Brookshire, 355 S.W.2d 36 (Mo. 1962). · cites it 3× “Section 509.200 RSMo 1949, V.A.M.S., provides that “In actions where exemplary or punitive damages are recoverable, the petition shall state separately the amount of such damages sought to be recovered.”
Thompson v. Hodge, 348 S.W.2d 11 (Mo. Ct. App. 1961). · cites it 2× “Section 509.200 R.S.Mo.1959, V.A.M.S.; Supreme Court Rule 55.”
Schieffer v. Decleene, 539 S.W.3d 798 (Mo. Ct. App. 2017). · cites it 2× “" Section 509.200; Rule 55.19; Marshall v. Brown , 608 S.”
Coleman v. Ziegler, 248 S.W.2d 610 (Mo. 1952). · cites it 3× “52 [Section 509.200 RSMo 1949, V.A.M.S.] which provides as follows: `When items of special damage are claimed, they shall be specifically stated.”
Marshall v. Brown, 608 S.W.2d 105 (Mo. Ct. App. 1980). · cites it 3× “Defendant argues that plaintiff’s petition made no claim for such damages and that the need for such surgery is wholly speculative.”
Young v. Mercantile Trust Co. Nat. Ass'n, 552 S.W.2d 247 (Mo. Ct. App. 1977). “Usually, special damages must be specifically pled, § 509.200, V.A.M.S. In the present case, the only special damages specifically alleged in plaintiff’s petition were detriment to her reputation in the economic community.”
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