Mo. Rev. Stat. » Chapter 540
Missouri Revised Statutes

Mo. Rev. Stat. § 540.300 (2026)

Grand jurors required to testify, when

✓ current as of May 2026
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  540.300.  Grand jurors required to testify, when. — Members of the grand jury may be required by any court to testify whether the testimony of a witness examined before such jury is consistent with or different from the evidence given by such witness before such court.  They may also be required to disclose the testimony given before them by any person, upon a complaint against such person for perjury, or upon his trial for such offense.

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(RSMo 1939 § 3922, A.L. 1989 S.B. 127, et al.)

Prior revisions: 1929 § 3533; 1919 § 3878; 1909 § 5086

Notes of Decisions
Cited in 6 cases (1 in the last 5 years), 1956–2025 · leading case: Mannon v. Frick, 295 S.W.2d 158 (Mo. 1956).
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Mannon v. Frick, 295 S.W.2d 158 (Mo. 1956). · cites it 6× “The purport of § 540.300 is that members of the grand jury may be required by any court to testify whether the testimony of a witness before such court is consistent with his or her prior testimony before the grand jury, and that they may also be required to testify similarly…”
State ex inf. Dalton v. Moody, 325 S.W.2d 21 (Mo. 1959). · cites it 4× ““No grand juror shall disclose any evidence given before the grand jury, nor the name of any witness who appeared before them, except when lawfully required to testify as a witness in relation thereto; * * § 540.300. “Members of the grand jury may be required by any court to…”
State v. McGee, 757 S.W.2d 321 (Mo. Ct. App. 1988). · cites it 2× “Although appellant had the opportunity to do so, he did not call these grand jurors to testify, as he could have done under § 540.300, RSMo 1986. If the trial court did have discretion to grant appellant the right to question the grand jury witnesses or the grand jurors as to…”
Doe v. Bell, 367 F. Supp. 3d 966 (E.D. Mo. 2019). · cites it 2× “One exception is found in § 540.300 R.S.Mo : Members of the grand jury may be required by any court to testify whether the testimony of a witness examined before such jury is consistent with or different from the evidence given by such witness before such court.”
Palmentere v. Campbell, 205 F. Supp. 261 (W.D. Mo. 1962). · cites it 2× “” Section 540.300 provides: “Members of the grand jury may be required by any court to testify whether the testimony of a witness examined before such jury is consistent with or different from the evidence given by such witness before such court; and they may also be required to…”
State of Missouri v. David Thompson (Mo. Ct. App. 2025). · cites it 2× “Under § 540.300, Thompson argues justice required allowing the grand jurors to watch the trial and attest to whether the law enforcement officer omitted that Thompson called 911 when testifying before the grand jury for purposes of 1 All statutory references are to RSMo (2016).”
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