Missouri Revised Statutes
Mo. Rev. Stat. § 534.200 (2026)
Proof required of complainant
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534.200. Proof required of complainant. — The complainant shall not be compelled to make further proof of the forcible entry or detainer than that he was lawfully possessed of the premises, and that the defendant unlawfully entered into and detained or unlawfully detained the same.
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(RSMo 1939 § 2844, A.L. 1945 p. 1089)
Prior revisions: 1929 § 2458; 1919 § 3006; 1909 § 7668
Notes of Decisions
Cited in 13
cases (4 in the last 5 years), 1973–2023 · leading case: Wells Fargo Bank, N.A. v. Smith, 392 S.W.3d 446 (Mo. 2013).
Wells Fargo Bank, N.A. v. Smith, 392 S.W.3d 446 (Mo. 2013). “These limitations on the substantive scope of Missouri’s unlawful detainer actions find current expression in section 534.200, RSMo, which provides: “The complainant shall not be compelled to make further proof of the forcible entry or de-tainer than that he was lawfully…”
State ex rel. Deutsche Bank Nat'l Trust Co. v. Chamberlain, 372 S.W.3d 24 (Mo. Ct. App. 2012). “Section 534.200 provides in pertinent part that: The complainant shall not be compelled to make further proof of the .”
Walker v. Anderson, 182 S.W.3d 266 (Mo. Ct. App. 2006). “Anderson was on “significant pain medication” at the time she executed the warranty deed and was unable to understand the legal ramifications of the transaction.”
Cent. Bank of Kansas City v. Mika, 36 S.W.3d 772 (Mo. Ct. App. 2001). “According to the Mikas, the bank was not “legally entitled to possession of the property,” as required by §§ 534.200 1 and 534.030 2 , RSMo 1994, because the *774 Bank did not obtain “legal title” to the property in that the Bank defrauded them into agreeing to the foreclosure…”
Nat'l Garment Co. v. City of Paris, 655 S.W.2d 515 (Mo. 1983). “It is § 534.200, RSMo 1978 that sets forth the nature of plaintiff’s case and the proof which it must make: That it “.”
Deborah a. Stratman & Timothy M. Stratman, Plaintiffs-respondents v. Hazel I. Wagner, 427 S.W.3d 915 (Mo. Ct. App. 2014). “Applicable Legal Principles In order to be entitled to summary judgment on their claim Tenant unlawfully detained the home, Lessors were required to prove as a matter of law that Lessors were “lawfully possessed” of the home, and that Tenant “unlawfully detained” the home.”
US Bank, NA v. Watson, 388 S.W.3d 233 (Mo. Ct. App. 2012). “3d at 28 , quoting Section 534.200. 1 The governing statutes also explicitly state: “[t]he merits of the title shall in nowise be inquired into, on any complaint which shall be exhibited by virtue of the provisions of this chapter.”
I-70 mobile City, Inc. v. Deidre Cartwright, 595 S.W.3d 161 (Mo. Ct. App. 2020). “Indeed, In an unlawful detainer action, under section 534.200, RSMo 2000[6], the complainant shall not be compelled to make further proof of the forcible entry or detainer than that he was lawfully possessed of the premises, and that the defendant unlawfully entered into and…”
Arzberger v. Grant, 500 S.W.2d 23 (Mo. Ct. App. 1973). “Under the last cited case (and § 534.200), plaintiffs made a pri-ma facie case, entitling them to judgment, by exhibiting their deeds and a showing that after the 30 day notice was given defendants refused to vacate the premises, all here supported by affidavits.”
Joe D. Brown, in his Capacity as Successor Tr. of the George E. Heard Revocable Trust, Dated February 24, 2000 v. Douglas Lee Barnes & Kyle Barnes, 641 S.W.3d 241 (Mo. Ct. App. 2021). “Section 534.200 limits the substantive scope of unlawful detainer actions by providing that “[t]he complainant shall not be compelled to make further proof of the forcible entry or detainer than that he was lawfully possessed of the premises, and that the defendant unlawfully…”
Melissa K. Espinosa, Tr. of the Melissa K. Espinosa Revocable Trust v. Eric Baker & Veronica Baker, 631 S.W.3d 631 (Mo. Ct. App. 2021). “200 governs the proof required by a complainant in an unlawful detainer action and provides that: “The complainant shall not be compelled to make further proof of the forcible entry or detainer than that he was lawfully possessed of the premises, and that the defendant…”
Green Street 2900 Investors, LLC v. The St. Louis Woodworks, Inc., 654 S.W.3d 380 (Mo. Ct. App. 2022). “200: “The complainant shall not be compelled to make further proof of the forcible entry or detainer than that he was lawfully possessed of the premises, and that the defendant unlawfully entered into and detained or unlawfully detained the same.”
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