Mo. Rev. Stat. » Chapter 57
Missouri Revised Statutes

Mo. Rev. Stat. § 57.275 (2026)

Dismissal of deputies, procedure

✓ current as of May 2026
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  57.275.  Dismissal of deputies, procedure. — 1.  Any full-time deputy sheriff upon dismissal shall be furnished with a written notice of the grounds for the dismissal.  Upon receipt of the written grounds for the dismissal, the deputy sheriff may request a hearing.  The request must be made to the sheriff, in writing, within three working days of receipt of the grounds for dismissal.  Such hearing shall take place before the hearing board to be appointed by the sheriff.  The sheriff shall schedule a closed hearing within a reasonable time but within thirty days after the written request was received by the sheriff.  A written report of the facts determined during the hearing shall be forwarded to the sheriff.  The sheriff will review the findings, and has the final decision-making authority.  Any law enforcement agency shall be deemed to be in compliance with this section if the agency:

  (1)  Has published and distributed department policies and procedures which include provisions for dismissal of deputy sheriffs or other employees;

  (2)  Provides a deputy sheriff who has been dismissed written notification of the grounds for the dismissal;

  (3)  Allows the officer to request and have a hearing; and

  (4)  Provides the officer with written results of such hearing.

  2.  The procedural requirements created pursuant to this section shall not be interpreted as creating any new substantive due process rights.  Nothing in this chapter shall be interpreted as conferring or creating an employment status for deputy sheriffs other than at-will status and nothing in this chapter shall be interpreted as depriving any person of any rights which are conferred as a matter of employment, including postemployment benefits such as workers' compensation and unemployment compensation.

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(L. 1998 S.B. 659)

(2004) Mandated hearing is not a contested case subject to judicial review under the Administrative Procedure Act.  McCoy v. Caldwell County, 145 S.W.3d 427 (Mo.banc).

Notes of Decisions
Cited in 13 cases (1 in the last 5 years), 2004–2024 · leading case: Kunzie v. City of Olivette, 184 S.W.3d 570 (Mo. 2006).
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Kunzie v. City of Olivette, 184 S.W.3d 570 (Mo. 2006). · cites it 2× “The county sheriff in McCoy fired two deputy sheriffs following the procedures in section 57.275. Id. Those procedures provided for written notice of the grounds for dismissal, a hearing upon request before an appointed board, and required the board to make a written report of…”
McCoy v. Caldwell Cnty., 145 S.W.3d 427 (Mo. 2004). · cites it 2× “In particular, they argue that the hearing board procedure set forth in section 57.275 satisfies the definition of a “contested case” for purposes of judicial review under section 536.”
David Barrett v. Cole Cnty., Missouri, 687 S.W.3d 685 (Mo. Ct. App. 2024). · cites it 42× “In addition to filing an appeal with the Cole County Commission, on a date not specified in the amended petition, Barrett requested a hearing pursuant to section 57.275. Section 57.275 permits a dismissed full-time deputy sheriff, within three working days of 3 receipt from the…”
Bruce v. Cole, No. 6:17-cv-03073 (W.D. Mo. Oct. 29, 2018). · cites it 3× “15, 2017) (citing Mo. Rev. Stat. § 57.275 ) (“The sheriff has the final decision-making authority to fire deputies.”
Curtis v. Christian Cnty., Missouri, No. 6:17-cv-03072 (W.D. Mo. Oct. 29, 2018). · cites it 3× “15, 2017) (citing Mo. Rev. Stat. § 57.275 ) (“The sheriff has the final decision-making authority to fire deputies.”
Klossing v. Cole, No. 6:17-cv-03064 (W.D. Mo. Oct. 29, 2018). · cites it 3× “15, 2017) (citing Mo. Rev. Stat. § 57.275 ) (“The sheriff has the final decision-making authority to fire deputies.”
Wells v. Cole, 355 F. Supp. 3d 841 (E.D. Mo. 2018). · cites it 2× “Mo. Rev. Stat. § 57.275 expressly states that deputies serve at the pleasure of the sheriff, but does not state that deputies are "subject to patronage dismissal.”
Mills v. Cole Do Not File in this Case - Case Consol., file in Case No. 18-CV-03241-SRB ., No. 6:18-cv-03245 (W.D. Mo. Nov. 30, 2018). · cites it 2× “Moreover, because the Court denies Defendants’ motion to dismiss, the Court does not need to and will not address whether a grant of qualified 5 Mo. Rev. Stat. § 57.275 expressly states that deputies serve at the pleasure of the sheriff, but does not state that deputies are…”
Burns v. Cole <b> <font Color=\red\">this Is Consol. With Case 6:18-cv-03246-srb. All Pleadings Are to Be Filed in This Case. </b> </font>", No. 6:18-cv-03241 (W.D. Mo. Nov. 30, 2018). · cites it 2× “Moreover, because the Court denies Defendants’ motion to dismiss, the Court does not need to and will not address whether a grant of qualified 5 Mo. Rev. Stat. § 57.275 expressly states that deputies serve at the pleasure of the sheriff, but does not state that deputies are…”
Denton v. Cole <b> <font color=\RED\"> Do Not File in this Case - Case Consol. (2018). “Moreover, because the Court denies Defendants’ 5 Mo. Rev. Stat. § 57.275 expressly states that deputies serve at the pleasure of the sheriff, but does not state that deputies are “subject to patronage dismissal.”
Clark v. Cole <b> <font color=\RED\"> Do Not File in this Case - Case Consol. (2018). “Moreover, because the Court denies Defendants’ 5 Mo. Rev. Stat. § 57.275 expressly states that deputies serve at the pleasure of the sheriff, but does not state that deputies are “subject to patronage dismissal.”
Gallant v. Cole <b> <font color=\RED\"> Do Not File in this Case - Case Consol. (2018). “Moreover, because the Court denies Defendants’ 5 Mo. Rev. Stat. § 57.275 expressly states that deputies serve at the pleasure of the sheriff, but does not state that deputies are “subject to patronage dismissal.”
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