Mo. Rev. Stat. » Chapter 516
Missouri Revised Statutes

Mo. Rev. Stat. § 516.145 (2026)

What actions within one year

✓ laws through the 2026 session (checked Sept. 2026)
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  516.145.  What actions within one year. — Within one year:  all actions brought by an offender, as defined in section 217.010, against the department of corrections or any entity or division thereof, or any employee or former employee for an act in an official capacity, or by the omission of an official duty.

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(L. 1990 H.B. 974)

(2000) Section is constitutional and does not violate equal protection, due process, or the prohibition against special legislation.  Cooper v. Minor, 16 S.W.3d 578 (Mo.banc).

Notes of Decisions
Cited in 17 cases (8 in the last 5 years), 1997–2025 · leading case: Kinder v. Missouri Dep't of Corr., 43 S.W.3d 369 (Mo. Ct. App. 2001).
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Kinder v. Missouri Dep't of Corr., 43 S.W.3d 369 (Mo. Ct. App. 2001). · cites it 27× “The trial court sustained the DOC’s motion for summary judgment which stated that the one-year statute of limitation contained in § 516.145, RSMo 1994, 1 applied thus bar *371 ring Kinder’s claim.”
Cooper v. Minor, 16 S.W.3d 578 (Mo. 2000). · cites it 25× “Appellant’s petition was dismissed on the ground that it was time-barred by section 516.145, RSMo 1994. 1 We hold (1) appellant’s cause of action accrued no later than his last day of segregation; (2) appellant’s cause of action was not tolled by filing administrative…”
Dilley v. Valentine, 401 S.W.3d 544 (Mo. Ct. App. 2013). · cites it 2× “2001), this court defined “act in an official capacity” in the context of section 516.145, the one-year statute of limitations governing suits by offenders against the Department of Corrections or its employees.”
Charron v. Thompson, 939 S.W.2d 885 (Mo. 1997). · cites it 4× “The circuit court dismissed his petition because the claim was barred by the following: (1) § 516.145 RSMo 1994, 1 the one-year statute of limitations governing inmate claims; (2) the official immunity doctrine; and (3) the public duty doctrine.”
Pruitt v. Missouri Dep't of Corr., 224 S.W.3d 630 (Mo. Ct. App. 2007). · cites it 8× “*631 Corrections filed a motion to dismiss the petition arguing that: (1) Count I was barred by the statute of limitations set forth in Section 516.145; 1 (2) the petition failed to state a cause of action upon which relief could be granted; and (3) Pruitt failed to exhaust his…”
Mullins v. Est. of Corbin, 66 S.W.3d 84 (Mo. Ct. App. 2001). “140, and actions by employees for failure to pay minimum wages or overtime compensation; and § 516.145 limits actions by offenders, as defined in § 217.”
Fuller v. Kemna, 317 S.W.3d 176 (Mo. Ct. App. 2010). · cites it 12× “The trial court sustained the motion to dismiss on January 9, 2009. This appeal followed. We affirm because Appellant was time barred from bringing the claims as the one-year statute of limitations, pursuant to section 516.”
Trent Berhow v. State of Missouri, 713 S.W.3d 521 (Mo. 2025). · cites it 14× “5 Section 516.145 dictates that “all actions brought by an offender … against the department of corrections or any entity or division thereof …” must be brought within one year of the alleged harm.”
Bey v. Carver, No. 4:23-cv-00347 (E.D. Mo. Mar. 12, 2024). · cites it 11× “See Mo. Rev. Stat. § 516.145 (‘Within one year: all actions brought by an offender .”
George F. Aldridge, Jr. v. Brian Hoskin, 645 S.W.3d 101 (Mo. Ct. App. 2022). · cites it 9× “against the department of corrections or any entity or division thereof, or any employee or former employee for an act in an official capacity, or by the omission of an official duty.”
Trent Berhow v. State of Missouri, No. WD86333 (Mo. Ct. App. Sept. 3, 2024). · cites it 8× “DOC moved to dismiss Berhow’s petition as untimely under § 516.145,2 prompting Berhow to file a motion for leave to amend his petition to dismiss DOC without prejudice and add the State as a party.”
Rice v. Boyd, No. 4:19-cv-01563 (E.D. Mo. Feb. 12, 2020). · cites it 6× “The Kinder court focused on the meaning of “an act in an official capacity[,]” and stated: The phrase ‘act in an official capacity’ means that a public servant is acting within the scope of what he or she is employed to do rather than being engaged in a personal frolic.”
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