Missouri Revised Statutes

Mo. Rev. Stat. § 547.020 (2026)

New trials

✓ current as of May 2026
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  547.020.  New trials — when granted. — The court may grant a new trial for the following causes, or any of them:

  (1)  When the jury has received any evidence, papers or documents, not authorized by the court, or the court has admitted illegal testimony, or excluded competent and legal testimony, or for newly discovered evidence;

  (2)  When the jury has been separated without leave of the court, after retiring to deliberate upon their verdict, or has been guilty of any misconduct tending to prevent a fair and due consideration of the case;

  (3)  When the verdict has been decided by means other than a fair expression of opinion on the part of all the jurors;

  (4)  When the court has misdirected the jury in a material matter of law;

  (5)  When the verdict is contrary to the law or evidence.

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(RSMo 1939 § 4124)

Prior revisions: 1929 § 3734; 1919 § 4078; 1909 § 5284

(1952) Where jurors during trial were transported by sheriff and deputy sheriffs to and were quartered in residence nineteen miles from courthouse, and doctors were called and administered "shots" to two jurors in presence of sheriff both at said residence and at courthouse and some of jurors retired to restroom while others remained outside all in presence of sheriff, there was no prejudicial error. State v. Rose (Mo.), 249 S.W.2d 324.

(1953) Where in burglary case sheriff, who was one of the state's main witnesses, was observed talking to juror about a burglary case after close of evidence but before submission and the state made no showing whatever that juror was not subjected to improper influence, the verdict against defendant should be set aside. State v. Jones, 363 Mo. 998, 255 S.W.2d 801.

(1956) Where juror on voir dire in robbery prosecution failed to disclose that accessories on his automobile had disappeared and testified that such accessories were of small value and that he had forgotten the incident, the verdict would not be disturbed. State v. Townzell (Mo.), 286 S.W.2d 785.

Notes of Decisions
Cited in 34 cases, 1953–2018 · leading case: State of Missouri v. Thomas A. Ess, 453 S.W.3d 196 (Mo. 2015).
State of Missouri v. Thomas A. Ess, 453 S.W.3d 196 (Mo. 2015). · cites it 8× “Defense counsel mentioned section 547.020 to the circuit court during the evidentiary hearing on the motion for new trial, contrary to the dissenting opinion’s claim that Ess failed to raise either of these statutes in conjunction with the motion for new trial.”
State v. Rios, 314 S.W.3d 414 (Mo. Ct. App. 2010). · cites it 8× “Analysis Section 547.020(2) 2 provides that the trial court may grant a new trial “[w]hen the jury has been separated without leave of the court, after retiring to deliberate upon their verdict, or has been guilty of any misconduct tending to prevent a fair and due consideration…”
State v. Harvey, 730 S.W.2d 271 (Mo. Ct. App. 1987). · cites it 14× “We also note that both jurors testified to listening to the radio, however, no questions were asked either by the state or by the defense about what the jurors may have heard or learned about the trial from the radio broadcasts.”
State v. Babb, 680 S.W.2d 150 (Mo. 1984). · cites it 6× “They may retire under the charge of an officer who, in case of a felony, shall be sworn to keep them together in some private or convenient room or place and not permit any person to speak or communicate with them, nor do so himself, unless by order of the court, or to ask them…”
State v. Shockley, 410 S.W.3d 179 (Mo. 2013). · cites it 2× “Shockley claims a violation of section 547.020 in the argument section of his brief (although he does not mention it in his point relied on).”
State v. Scott, 200 S.W.3d 41 (Mo. Ct. App. 2006). · cites it 6× “Further support for the propriety of a trial court's reconsideration of its ruling on a motion to suppress is found in the trial court's statutory authority to grant a new trial based upon grounds identified in the motion for new trial.”
State v. Johnson, 586 S.W.2d 437 (Mo. Ct. App. 1979). · cites it 3× “Although the sheriff gave permission to have a drink, some of the jurors did observe the trial judge sitting at a table across the room.”
Fonville v. State, 563 S.W.3d 794 (Mo. Ct. App. 2018). · cites it 4× “30] Fonville argues that reasonably competent counsel would have then presented affidavits or testimony to the trial court to demonstrate that, pursuant to section 547.020 5 , a new trial was necessary because "the verdict [was] decided by means other than a fair expression of…”
State v. Hayes, 637 S.W.2d 33 (Mo. Ct. App. 1982). · cites it 5× “The officer shall not communicate to any person the state of their deliberations; provided, however, when there are women members of a jury, they may be kept separate from the men members of the jury, if any, and under the charge of a woman officer of the court during any time…”
State v. Herndon, 224 S.W.3d 97 (Mo. Ct. App. 2007). · cites it 3× “]” Section Section 547.020(2), RSMo 2000. The circuit court has broad discretion in determining whether or not the state has met its burden of establishing that the communication was harmless.”
State v. Kelly, 851 S.W.2d 693 (Mo. Ct. App. 1993). · cites it 3× “1 He further observed that the location of streets in the City was or could be a matter of common knowledge among City residents, which the jurors were, and that jurors bring their experiences with them, including their knowledge of City streets.”
State v. White, 138 S.W.3d 783 (Mo. Ct. App. 2004). · cites it 4× “A new trial is warranted under Section 547.020(2) when jury misconduct tends to prevent a fair and due consideration of the case.”
— Mo. Rev. Stat. § 547.020(1) — 2 cases
State v. Foster, 490 S.W.2d 659 (Mo. Ct. App. 1973).
State v. Viviano, 882 S.W.2d 748 (Mo. Ct. App. 1994).
— Mo. Rev. Stat. § 547.020(2) — 11 cases
State v. Rios, 314 S.W.3d 414 (Mo. Ct. App. 2010). “Analysis Section 547.020(2) 2 provides that the trial court may grant a new trial “[w]hen the jury has been separated without leave of the court, after retiring to deliberate upon their verdict, or has been guilty of any misconduct tending to prevent a fair and due consideration…”
State of Missouri v. Thomas A. Ess, 453 S.W.3d 196 (Mo. 2015). “Defense counsel mentioned section 547.020 to the circuit court during the evidentiary hearing on the motion for new trial, contrary to the dissenting opinion’s claim that Ess failed to raise either of these statutes in conjunction with the motion for new trial.”
State v. Herndon, 224 S.W.3d 97 (Mo. Ct. App. 2007). “]” Section Section 547.020(2), RSMo 2000. The circuit court has broad discretion in determining whether or not the state has met its burden of establishing that the communication was harmless.”
State v. White, 138 S.W.3d 783 (Mo. Ct. App. 2004). “A new trial is warranted under Section 547.020(2) when jury misconduct tends to prevent a fair and due consideration of the case.”
State v. Martinelli, 972 S.W.2d 424 (Mo. Ct. App. 1998).
— Mo. Rev. Stat. § 547.020(5) — 1 case
State of Missouri v. Cassandra E. Johnston, 450 S.W.3d 457 (Mo. Ct. App. 2014).
Annotations are extracted automatically from the opinions in the Syfert caselaw corpus and ranked by authority, recency, and treatment. Dots show Syfertize treatment of the citing case itself.