Mo. Rev. Stat. » Chapter 524
Missouri Revised Statutes

Mo. Rev. Stat. § 524.160 (2026)

Defendant may recover compensation for improvements, when

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  524.160.  Defendant may recover compensation for improvements, when. — If a judgment or decree of dispossession shall be given in an action for the recovery of possession of premises, or in any real action in favor of a person having a better title thereto, against a person in the possession, held by himself or by his tenant, of any lands, tenements or hereditaments, such person may recover, in a court of competent jurisdiction, compensation for all improvements made by him in good faith on such lands, tenements or hereditaments, prior to his having had notice of such adverse title.

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(RSMo 1939 § 1548)

Prior revisions: 1929 § 1384; 1919 § 1834; 1909 § 2401

(1979) A claim under this section must fail if it can be shown the improvements were made with notice to an adverse title.  Morris v. Ulbright (A.), 591 S.W.2d 245.

Notes of Decisions
Cited in 19 cases, 1957–2010 · leading case: Snadon v. Gayer, 566 S.W.2d 483 (Mo. Ct. App. 1978).
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Snadon v. Gayer, 566 S.W.2d 483 (Mo. Ct. App. 1978). · cites it 5× “§§ 524.160 and 524.170. 1 On March 20,1975, the court filed a memorandum opinion in which he initially acknowledged having “had great difficulty in deciding this case .”
State ex rel. Shaul v. Jones, 335 S.W.2d 468 (Mo. Ct. App. 1960). · cites it 8× “The parties agree that the action before respondent was brought pursuant to the authority and provisions of Section 524.160 RSMo 1949, 35 V.A.M.S. No question is presented concerning the sufficiency of the petition to comply with Section 524.”
Steen v. Colombo, 722 S.W.2d 648 (Mo. Ct. App. 1987). · cites it 5× “The judgment was premised on the alleged right of the trial court to order the forced sale of the real estate, by reason of the provisions of § 524.160, et seq., 1 which statutes constitute the so-called “betterment act.”
Weatherwax v. Redding, 953 S.W.2d 162 (Mo. Ct. App. 1997). · cites it 3× “Defendants based their counterclaim on § 524.160, RSMo 1994, which reads: “If a judgment or decree of dispossession shall be given in an action for the recovery of possession of premises, or in any real action in favor of a person having a better title thereto, against a person…”
Crossland v. Thompson, 317 S.W.3d 635 (Mo. Ct. App. 2010). · cites it 2× “Count III asked the court to award Thomas the value of his improvements to the property pursuant to § 524.160 RSMo (2000). Count IV asked the court to award Thomas the difference in the property’s value before and after the improvements, whichever was greater, to cure any unjust…”
Flaspohler v. Hoffman, 652 S.W.2d 703 (Mo. Ct. App. 1983). · cites it 2× “Plaintiff’s Coant III Plaintiff pleaded alternatively that if no relief were granted under Counts I and II she was entitled to a judgment for the value of improvements made on the disputed tract pursuant to § 524.160 RSMo 1978. The court entered judgment against plaintiff, and…”
M & P Enter., Inc. v. Transamerica Fin. Servs., 944 S.W.2d 154 (Mo. 1997). “In Count V of the petition, the purchaser seeks to recover the cost of improvements made to the property under the Missouri betterment statute, § 524.160, and under general principles of the common law of unjust enrichment.”
Toalson v. Madison, 307 S.W.2d 32 (Mo. Ct. App. 1957). · cites it 3× “The provisions of Section 524.160 RSMo 1949, V.A.M.S., known as the betterments statute, is the section upon which defendant relies.”
Morris v. Ulbright, 591 S.W.2d 245 (Mo. Ct. App. 1979). · cites it 4× “Dorothy and Ralph concede in their brief that they knew Morris was claiming title prior to making any improvements but state the question presented in this case is whether or not the claim of ownership on the part of Morris rose to the statutory requirement of notice in §…”
Chicago Title Ins. Co. v. Farmers Ins. Co., 734 S.W.2d 887 (Mo. Ct. App. 1987). · cites it 4× “Appellant cites the Missouri Betterment Statute, § 524.160 RSMo 1978 1 in support of its position that Farmers was unjustly enriched.”
City of Poplar Bluff v. Knox, 410 S.W.2d 100 (Mo. Ct. App. 1966). · cites it 2× “§ 524.160. 1 Although counsel has directed us to no authority from any jurisdiction dealing with the problem at hand, we are of the opinion the rule and statute has no application where the property concerned, as here, is a *103 dedicated public street.”
Buschmeyer v. Eikermann, 378 S.W.2d 468 (Mo. 1964). · cites it 2× “Appellants sought in a counterclaim to recover for such improvements by the enforcement of an equitable right and, alternatively, to recover for such improvements under the terms of Section 524.160 and C.R. 89.16 (the “betterment” statute or rule).”
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