Mo. Rev. Stat. » Chapter 544
Missouri Revised Statutes

Mo. Rev. Stat. § 544.200 (2026)

Officer may break open doors

✓ current as of May 2026
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  544.200.  Officer may break open doors. — To make an arrest in criminal actions, the officer may break open any outer or inner door or window of a dwelling house or other building, or any other enclosure, if, after notice of his office and purpose, he be refused admittance.

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(RSMo 1939 § 3889)

Prior revisions: 1929 § 3499; 1919 § 3844; 1909 § 5052

(1968) Held facts justified forcible entry and arrest without warrant. State v. Novak (Mo.), 428 S.W.2d 585.

Notes of Decisions
Cited in 11 cases, 1963–2014 · leading case: State of Missouri v. Christopher Eric Hunt, 451 S.W.3d 251 (Mo. 2014).
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State of Missouri v. Christopher Eric Hunt, 451 S.W.3d 251 (Mo. 2014). · cites it 20× “Section 544.200 privileges officers to break doors and windows to effectuate arrests when police presence is first announced and admittance is refused.”
Payton v. New York, 445 U.S. 573 (1980). · cites it 2× “§ 99-3-11 (1973); Mo. Rev. Stat. § 544.200 (1978); Neb. Rev.”
State v. Parrish, 852 S.W.2d 426 (Mo. Ct. App. 1993). · cites it 8× “art I, § 15, and § 544.200, RSMo 1986, 1 because the police did not announce their authority and purpose prior to forcing their way into the house.”
State v. Gibbs, 224 S.W.3d 126 (Mo. Ct. App. 2007). · cites it 11× “200 Gibbs also contends that the failure to knock and announce violated section 544.200, RSMo 2000, which provides: To make an arrest in criminal actions, the officer may break open any outer or inner door or window of a dwelling house or other building, or any other enclosure,…”
Green v. Denison, 738 S.W.2d 861 (Mo. 1987). · cites it 3× “The plaintiffs assert that the officers violated Section 544.200, RSMo 1986, reading as follows: To make an arrest in criminal actions, the officer may break open any outer or inner door or window of a dwelling house or other building, or any other enclosure, if after notice of…”
Ker v. California, 374 U.S. 23 (1963). “Code § 2471; Mo. Rev. Stat. § 544.200 ; Mont. Rev. Code § 94-6011; Neb.”
State v. Corpier, 793 S.W.2d 430 (Mo. Ct. App. 1990). · cites it 2× “In the instant case the evidence showed that although Deputy Potter identified himself, he failed to provide notice of his purpose to arrest the defendant as required by Mo.Rev.Stat. § 544.200 (1985). See State v.”
State v. Peters, 695 S.W.2d 140 (Mo. Ct. App. 1985). · cites it 2× “It may even be that when the door is opened to an announced police presence with an announced purpose to arrest [a decorum required by our § 544.200, RSMo 1978, for any home arrest — even with a warrant], the consent to enter is given unless expressly refused.”
State v. Novak, 428 S.W.2d 585 (Mo. 1968). · cites it 2× “An officer may break open any outer or inner door or window of a dwelling house in order to make an arrest if, after notice of his office and purpose, he be refused admittance, Section 544.200, V. A.M.S., Miller v. United States, supra, 357 U.”
Rice v. Barnes, 966 F. Supp. 877 (W.D. Mo. 1997). · cites it 2× “§ 3109 or Mo.Rev. Stat. § 544.200, which both permit officers to break open doors to execute a search warrant after notice of authority and purpose.”
State of Missouri v. Christopher Eric Hunt (Mo. Ct. App. 2014). · cites it 8× “In addition, according to Section 544.200, Defendant had authority to break open any outer or inner door or window of a dwelling house in effecting an arrest.”
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