Mo. Rev. Stat. » Chapter 534
Missouri Revised Statutes

Mo. Rev. Stat. § 534.210 (2026)

Merits of title cannot be inquired into

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  534.210.  Merits of title cannot be inquired into. — The 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.

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(RSMo 1939 § 2853)

Prior revisions: 1929 § 2467; 1919 § 3015; 1909 § 7677

(2013) Section does not create irrebuttable presumption that title is proven merely by filing an unlawful detainer action and thus does not violate either due process or equal protection.  Wells Fargo Bank, N.A. v. Smith, 392 S.W.3d 446 (Mo.banc).

Notes of Decisions
Cited in 19 cases (3 in the last 5 years), 1970–2023 · leading case: Wells Fargo Bank, N.A. v. Smith, 392 S.W.3d 446 (Mo. 2013).
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Wells Fargo Bank, N.A. v. Smith, 392 S.W.3d 446 (Mo. 2013). · cites it 69× “The Smiths argue that, because section 534.210, RSMo, 1 is unconstitutional, summary judgment was improper and the case should be remanded for consideration of their equitable defenses and counterclaims concerning the validity of Wells Fargo’s title.”
Fannie Mae v. My Quang Truong, 361 S.W.3d 400 (Mo. 2012). · cites it 8× “As this case illustrates, the statutorily mandated rush to a judgment in unlawful detainer actions sacrifices the truth underlying the case.”
State ex rel. Deutsche Bank Nat'l Trust Co. v. Chamberlain, 372 S.W.3d 24 (Mo. Ct. App. 2012). · cites it 6× “) A specific example of “further proof’ a complainant shall not be compelled to make is set forth in section 534.210 which provides that: The merits of title shall in nowise be inquired into, on any complaint which shall be exhibited by virtue of the provisions of this chapter.”
Walker v. Anderson, 182 S.W.3d 266 (Mo. Ct. App. 2006). · cites it 5× “See also Section 534.210, RSMo 2000 (“The 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.”
Moser v. Cline, 214 S.W.3d 390 (Mo. Ct. App. 2007). · cites it 2× “Because the trial court found for the Clines in their breach of implied warranty of habitability claim and the Clines were prohibited from asserting the claim as a defense or counterclaim to the Mosers’ unlawful detainer claim, the trial court’s award of $200 in damages to the…”
Fed. Nat'l Mortg. Ass'n v. Wilson, 409 S.W.3d 490 (Mo. Ct. App. 2013). · cites it 2× “Section 534.210 explicitly states that “[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.”
McNeill v. McNeill, 456 S.W.2d 800 (Mo. Ct. App. 1970). · cites it 4× “In arguing this assignment, defendants complain that by those rulings the trial court in effect “refused to permit the defendants to place title in issue and refused to permit them to counterclaim for improvements made upon the [farm] during their occupancy.” That indeed was the…”
Davis v. Stewart Title Guar. Co., 726 S.W.2d 839 (Mo. Ct. App. 1987). · cites it 2× “” The insurer argues, however, that the letter of transmittal appended to the transcript of judgment “had absolutely no relevance to the issue of notice,” but rather was an expression of an adjudication beyond the jurisdiction of the associate circuit court — the validity of the…”
Henze v. Shell Oil Co., 758 S.W.2d 93 (Mo. Ct. App. 1988). · cites it 3× “” Section 534.210 RSMo 1986. Second, defendant’s attempted counterclaim for specific performance was dismissed by the court before trial.”
Cmty. Bank of Raymore v. Patterson Oil Co., 463 S.W.3d 381 (Mo. Ct. App. 2015). · cites it 2× “Section 534.210 explicitly states that “[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.”
US Bank, NA v. Watson, 388 S.W.3d 233 (Mo. Ct. App. 2012). · cites it 2× “” Section 534.210. The summary nature of unlawful detainer prohibits litigants from introducing issues related to title or matters of equity as a claim or a defense.”
Mortg. Assocs., Inc. v. Wiley, 650 S.W.2d 13 (Mo. Ct. App. 1983). · cites it 2× “” And, Section 534.210 V.A.M.S. declares: “The 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.”
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