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Missouri Revised Statutes

Mo. Rev. Stat. § 510.180 (2026)

Consolidation of actions

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  510.180.  Consolidation of actions — separate trials of issues. — 1.  Whenever several suits founded alone upon liquidated demands shall be pending in the same court by the same plaintiff, against the same defendant, or whenever several such suits are pending in the same court, by the same plaintiff, against several defendants, the court in which the same shall be prosecuted may, in its discretion, if it appear expedient, order such suits to be consolidated into one action.

  2.  The court in furtherance of convenience or to avoid prejudice may order a separate trial of any claim, cross-claim, counterclaim, or third-party claim, or of any separate issue or of any number of claims, cross-claims, counterclaims, third-party claims, or issues.

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(RSMo 1939 §§ 1094, 1102, A.L. 1943 p. 353 § 97)

Prior revisions: 1929 §§ 943, 951; 1919 §§ 1393, 1401; 1909 §§ 1963, 1971

Notes of Decisions
Cited in 29 cases, 1952–1992 · leading case: Stacy v. Truman Med. Ctr., 836 S.W.2d 911 (Mo. 1992).
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Stacy v. Truman Med. Ctr., 836 S.W.2d 911 (Mo. 1992). · cites it 4× “Defendant TMC contends that the trial court, by deferring the sovereign immunity issue to the post-trial rulings, bifurcated the trial under section 510.180. Furthermore, defendant claims section 511.”
State ex rel. State High. Comm'n v. Hammel, 290 S.W.2d 113 (Mo. 1956). · cites it 4× “In that situation the trial court, in the exercise of its discretion, may order such separate trial, Section 510.180, subd. 2, and in a trial before the court, “the court may order a separate judgment entered which shall be deemed .”
Emery v. Brown Shoe Co., 287 S.W.2d 761 (Mo. 1956). · cites it 3× “be had, in accordance with the provisions of Section 510.180(2) RSMo 1949, V.A.M.S., on the issue of whether or not defendant was estopped from asserting the affirmative defense contained in its answer.”
City of St. Louis v. Kisling, 318 S.W.2d 221 (Mo. 1958). · cites it 3× “Perhaps the provisions of Section 510.180(2) RSMo 1949, V.A.M.S., would be available in situations of this nature.”
Weir ex rel. Weir v. Brune, 262 S.W.2d 597 (Mo. 1953). · cites it 2× “§ 510.180, and Buie 3.29. Missouri statutory references are to- BSMo 1949.”
Plaza Express Co. v. Galloway, 280 S.W.2d 17 (Mo. 1955). · cites it 2× “As to contention (3) that the defendants each have a constitutional right to a separate jury trial as to the fact issue of whether the injuries resulted in deceased's death: In support of this contention defendants respondents cite Art.”
Brown v. Sloan's Moving & Storage Co., 296 S.W.2d 20 (Mo. 1956). · cites it 3× “Section 510.180(2), RSMo. 1949, y.A.M.S. Plaintiff could state her claim , (Cotint I) upon the bailment, the gist of which claim was negligence, and, without .”
State ex rel. State High. Comm'n v. Curtis, 283 S.W.2d 458 (Mo. 1955). · cites it 3× “See Section 510.180 RSMo 1949, V.A.M.S.; and 42 V.”
Agnew v. Union Constr. Co., 291 S.W.2d 106 (Mo. 1956). · cites it 3× “Section 510.180 provides: “2. The court in furtherance of convenience or to avoid prejudice may order .”
Hays v. Proctor, 404 S.W.2d 756 (Mo. Ct. App. 1966). · cites it 3× “Defendant Strebler next complains about the action of the court in sustaining a motion for separate trial of his cross-claim against Hodgson.”
Hahn v. Hahn, 297 S.W.2d 559 (Mo. 1957). · cites it 2× “Section 510.180 permits the consolidation of actions and further provides that “the court in furtherance of convenience or to avoid prejudice may order a separate trial of any claim, cross-claim, counter-claim, or third-party claim, or any separate issue or of any number of…”
Amitin v. Izard, 252 S.W.2d 635 (Mo. Ct. App. 1952). · cites it 3× “This was in accordance with the authority granted in Section 510.180(2) RSMo 1949, V.A.M.S. Under Supreme Court Rule 3.”
Show all 29 citing cases →
Mo. Rev. Stat. § 510.180(2): 11 cases
Emery v. Brown Shoe Co., 287 S.W.2d 761 (Mo. 1956). “be had, in accordance with the provisions of Section 510.180(2) RSMo 1949, V.A.M.S., on the issue of whether or not defendant was estopped from asserting the affirmative defense contained in its answer.”
City of St. Louis v. Kisling, 318 S.W.2d 221 (Mo. 1958). “Perhaps the provisions of Section 510.180(2) RSMo 1949, V.A.M.S., would be available in situations of this nature.”
Brown v. Sloan's Moving & Storage Co., 296 S.W.2d 20 (Mo. 1956). “Section 510.180(2), RSMo. 1949, y.A.M.S. Plaintiff could state her claim , (Cotint I) upon the bailment, the gist of which claim was negligence, and, without .”
Amitin v. Izard, 252 S.W.2d 635 (Mo. Ct. App. 1952). “This was in accordance with the authority granted in Section 510.180(2) RSMo 1949, V.A.M.S. Under Supreme Court Rule 3.”
Adams v. Adams, 294 S.W.2d 18 (Mo. 1956).
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