Missouri Revised Statutes

Mo. Rev. Stat. § 516.170 (2026)

May delay filing of action, when

✓ current as of May 2026
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  516.170.  May delay filing of action, when. — Except as provided in section 516.105, if any person entitled to bring an action in sections 516.100 to 516.370 specified, at the time the cause of action accrued be either within the age of twenty-one years, or mentally incapacitated, such person shall be at liberty to bring such actions within the respective times in sections 516.100 to 516.370 limited after such disability is removed.

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(RSMo 1939 § 1020, A.L. 1976 S.B. 470, A.L. 1983 S.B. 44 & 45, A.L. 1990 H.B. 974)

Prior revisions: 1929 § 868; 1919 § 1323; 1909 § 1894

(1977) Statute of limitations is tolled while plaintiff is actually imprisoned by any proper authority and statute starts to run when plaintiff is released on parole. Jepson v. Stubbs (Mo.), 555 S.W.2d 307.

(1984) This section was held to toll the five year statute of limitations in section 516.120 during the course of a ward's incompetence, despite the appointment of a guardian. Mason v. Ford Motor Co. (8th Cir.) 755 F.2d 120.

(1985) Held, that even though plaintiff could have, by reason of section 507.115, RSMo, filed his action when he became eighteen years of age without the necessity of a guardian, curator, or next friend, the two-year limitation was nonetheless tolled, by reason of this statute, until plaintiff reached age twenty-one. Crawford v. Fenton (A.), 701 S.W.2d 772.

(1987) The provisions of section 516.170, RSMo, protecting the rights of persons under disability, apply to any statute of limitations borrowed under the provisions of section 516.190, RSMo. Dorris v. McClanahan, 725 S.W.2d 870 (Mo.banc).

Notes of Decisions
Cited in 99 cases (6 in the last 5 years), 1960–2026 · leading case: Batek v. Curators of the Univ. of Missouri, 920 S.W.2d 895 (Mo. 1996).
Batek v. Curators of the Univ. of Missouri, 920 S.W.2d 895 (Mo. 1996). · cites it 38× “She contends, however, that the statute was tolled until her twenty-first birthday under section 516.170, RSMo 1994, which provides that certain actions are tolled during a plaintiffs minority: Except as provided in section 516.”
Dorris v. McClanahan, 725 S.W.2d 870 (Mo. 1987). · cites it 48× “§ 516.170, RSMo 1986. In Trzecki v. Gruenewald, 532 S.”
Powel v. Chaminade Coll. Preparatory, Inc., 197 S.W.3d 576 (Mo. 2006). · cites it 12× “Section 516.170; Strahler v. St. Luke's Hospital, 706 S.”
Jepson v. Stubbs, 555 S.W.2d 307 (Mo. 1977). · cites it 18× “120(4)], 1 such actually was not the case because § 516.170 provides that the statute of limitations is tolled for persons imprisoned during the period immediately subsequent to defendant’s negligence.”
Graham v. McGrath, 243 S.W.3d 459 (Mo. Ct. App. 2007). · cites it 32× “Section 516.170. Although the parties agree that the statute of limitations was tolled until Plaintiff reached the age of twenty one, they disagree about when the Plaintiffs cause of action accrued.”
Kellog v. Kellog, 989 S.W.2d 681 (Mo. Ct. App. 1999). · cites it 30× “It further found that plaintiff failed to raise a genuine issue of fact that he was “mentally incapacitated”, as that term is used in the tolling statute, Section 516.170 RSMo (1994), for the two years following his injury.”
Wheeler v. Briggs, 941 S.W.2d 512 (Mo. 1997). · cites it 30× “170, RSMo 1994, which tolls the statute of limitations for individuals who are minors or who are mentally incapacitated, to the extent that the statute excepts from its tolling provisions actions for medical malpractice. Plaintiff JoAnn Wheeler (Conservator), as conservator of…”
Strahler v. St. Luke's Hosp., 706 S.W.2d 7 (Mo. 1986). · cites it 10× “Section 516.170, RSMo Cum.Supp.1984. The prosecution of an action by a guardian or next friend is an option available to the minor; failure of a next friend to bring the action during minority does not, however, destroy the cause of action, generally speaking.”
Thompson Ex Rel. Thompson v. Crawford, 833 S.W.2d 868 (Mo. 1992). · cites it 8× “Plaintiff cites section 516.170, RSMo 1986, to support this argument, which states in pertinent part as follows: If any person entitled to bring an action in sections 516.”
Harris v. Hollingsworth, 150 S.W.3d 85 (Mo. Ct. App. 2004). · cites it 12× “Plaintiff would have attained the age of 21 years (the age of majority pursuant to section 516.170) in approximately 1984. At that time, the applicable statutes of limitation were section 516.”
Thompson v. Bond, 421 F. Supp. 878 (W.D. Mo. 1976). · cites it 8× “” The so-called “saving statute”, Mo.Rev. Stat. § 516.170, provides: If any person entitled to bring an action in sections 516.”
Lough Ex Rel. Lough v. Rolla Women's Clinic, Inc., 866 S.W.2d 851 (Mo. 1993). · cites it 6× “" § 516.170, RSMo 1986 (emphasis added). In 1990, the disability of imprisonment was removed from § 516.”
— Mo. Rev. Stat. § 516.170(1939) — 1 case
Millsaps v. McKee (E.D. Mo. 2019).
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