Missouri Revised Statutes

Mo. Rev. Stat. § 562.071 (2026)

Duress

✓ current as of May 2026
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  562.071.  Duress. — 1.  It is an affirmative defense that the defendant engaged in the conduct charged to constitute an offense because he or she was coerced to do so, by the use of, or threatened imminent use of, unlawful physical force upon him or her or a third person, which force or threatened force a person of reasonable firmness in his situation would have been unable to resist.

  2.  The defense of "duress" as defined in subsection 1 is not available:

  (1)  As to the crime of murder;

  (2)  As to any offense when the defendant recklessly places himself or herself in a situation in which it is probable that he or she will be subjected to the force or threatened force described in subsection 1 of this section.

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(L. 1977 S.B. 60, A.L. 2014 S.B. 491)

Effective 1-01-17

(1984) Duress is not available as a defense to first degree felony murder. State v. Rumble (Mo. banc), 680 S.W.2d 939.

Notes of Decisions
Cited in 33 cases (2 in the last 5 years), 1980–2024 · leading case: State v. Isa, 850 S.W.2d 876 (Mo. 1993).
State v. Isa, 850 S.W.2d 876 (Mo. 1993). · cites it 5× “Section 562.071, RSMo 1986. In doing so, the statute limited those circumstances under which the defense of duress will be recognized in the State of Missouri.”
State v. Dulany, 781 S.W.2d 52 (Mo. 1989). · cites it 3× “Section 562.071, RSMo 1986. Defendant also claims ineffective counsel for failing to cross-examine two witnesses concerning their ill feelings for her, failure to call witnesses requested by defendant and limiting her trial testimony.”
State v. Rumble, 680 S.W.2d 939 (Mo. 1984). · cites it 6× “Clair we simply reaffirmed the common law rule that duress is not available as a defense to the crime of murder: section 562.071 mirrors precisely the perimeters of the rule—as defined in St.”
State v. Juarez, 26 S.W.3d 346 (Mo. Ct. App. 2000). · cites it 6× “We *350 reverse his conviction for armed criminal action, however, because we find that Section 562.071 unambiguously permits submission of duress as an affirmative defense to the crime of armed criminal action, and remand for further proceedings consistent with this opinion.”
State of Missouri, Plaintiff-respondent v. Angela Megan Guinn, 453 S.W.3d 846 (Mo. Ct. App. 2014). · cites it 6× “It is an affirmative defense that the defendant engaged in the conduct charged to constitute an offense because he was coerced to do so, by the use of, or threatened imminent use of, unlawful physical force upon him or a third person, which force or threatened force a person of…”
State v. Gullett, 606 S.W.2d 796 (Mo. Ct. App. 1980). · cites it 2× “030) or duress (§ 562.071) the burden is on the defendant.”
State v. Baker, 598 S.W.2d 540 (Mo. Ct. App. 1980). · cites it 2× “The threshold question in this case is the availability of the defense of necessity in the law of Missouri.”
State v. Copeland, 928 S.W.2d 828 (Mo. 1996). “banc 1993); § 562.071. Our legislature has authorized the defense of battered spouse syndrome in matters of self-defense.”
State v. Ianniello, 671 S.W.2d 298 (Mo. Ct. App. 1984). · cites it 3× “” § 562.071 RSMo 1978. Defendant’s evidence that he suffered from Dyslexia, a reading disability, and that he knew Morris had committed strong arm robbery in the past is insufficient proof that he was coerced to participate in the shooting.”
United States v. Larry Wayne Lafleur, United States of Am. v. Nick Michael Holm, 971 F.2d 200 (9th Cir. 1992). “§ 13-412(C); Colo. Rev.Stat. § 18-1-708; Ga.Code Ann.”
State v. Brown, 58 S.W.3d 649 (Mo. Ct. App. 2001). · cites it 2× “” Section 562.071. The coercion, to constitute a defense, must be present, imminent and impending, and of such a nature as to induce a well grounded apprehension of death or serious bodily injury.”
State v. Coats, 835 S.W.2d 430 (Mo. Ct. App. 1992). · cites it 2× “§ 562.071 RSMo 1986. Defendant claims that the presence of three muggers coerced him into kicking Littlejohn a final time.”
— Mo. Rev. Stat. § 562.071(2) — 1 case
State v. Proctor, 585 N.W.2d 841 (Iowa 1998).
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