570.020. Determination of value. — For the purposes of this chapter, the value of property shall be ascertained as follows:
(1) Except as otherwise specified in this section, "value" means the market value of the property at the time and place of the crime, or if such cannot be satisfactorily ascertained, the cost of replacement of the property within a reasonable time after the crime. If the victim is a merchant, and the property is a type that the merchant sells in the ordinary course of business, then the property shall be valued at the price that such merchant would normally sell such property;
(2) Whether or not they have been issued or delivered, certain written instruments, not including those having a readily ascertainable market value such as some public and corporate bonds and securities, shall be evaluated as follows:
(a) The value of an instrument constituting evidence of debt, such as a check, draft or promissory note, shall be deemed the amount due or collectible thereon or thereby, such figure ordinarily being the face amount of the indebtedness less any portion thereof which has been satisfied;
(b) The value of any other instrument which creates, releases, discharges or otherwise affects any valuable legal right, privilege or obligation shall be deemed the greatest amount of economic loss which the owner of the instrument might reasonably suffer by virtue of the loss of the instrument;
(3) When the value of property cannot be satisfactorily ascertained pursuant to the standards set forth in subdivisions (1) and (2) of this section, its value shall be deemed to be an amount less than seven hundred fifty dollars.
Notes of Decisions
Cited in
41
cases (
4 in the last 5 years), 1981–2025 · leading case:
State v. Brown, 457 S.W.3d 772 (Mo. Ct. App. 2014).
State v. Brown, 457 S.W.3d 772 (Mo. Ct. App. 2014).
· cites it 37× “We agree with the defendant that section 570.020 RSMo. (Supp.2013) abrogates the rule stated in Napper, which is an example of the “continuing and vexing” valuation problems that existed prior to enactment of section 570.”
State v. Johnson, 461 S.W.3d 842 (Mo. Ct. App. 2015).
· cites it 11× “Section 570.020 defines value as “the market value of the property at the time and place of the crime, or if such value cannot be satisfactorily ascertained, the cost of replacement of the property within a reasonable time after the crime.”
State v. Calicotte, 78 S.W.3d 790 (Mo. Ct. App. 2002).
· cites it 9× “Section 570.020 defines value as “the market value of the property at the time and place of the crime.”
State v. Foster, 762 S.W.2d 51 (Mo. Ct. App. 1988).
· cites it 11× “” Section 570.020(1) RSMo 1986. The state offered no evidence of the value of the items taken at the time and place of the crime.”
State v. Boyd, 91 S.W.3d 727 (Mo. Ct. App. 2002).
· cites it 4× “However, Section 570.020 clearly states that “value” means market value at the time and place of the crime, in this case, December 7, 2000.”
State v. Slocum, 420 S.W.3d 685 (Mo. Ct. App. 2014).
· cites it 6× ““Absent substantial evidence as to the value, an essential element of the felony stealing charge is not proved.”
State v. Hall, 56 S.W.3d 475 (Mo. Ct. App. 2001).
· cites it 3× ““In Missouri, the purchase price and the age of an item are sufficient to establish its value under § 570.020.” State v. Merchant, 871 S.W.2d 102, 104 (Mo.”
State v. Weekley, 92 S.W.3d 327 (Mo. Ct. App. 2002).
· cites it 2× “Section 570.020 provides that the value of stolen property is “the market value of the property at the time and place of the crime, or if such cannot be satisfactorily ascertained, the cost of replacement of the property within a reasonable time after the crime[.”
Woolford v. State, 58 S.W.3d 87 (Mo. Ct. App. 2001).
· cites it 2× “…of Chapter 570, value is defined as "the market value of the property at the time and place of the crime....” Section 570.020(1).”
State v. Williams, 643 S.W.2d 3 (Mo. Ct. App. 1982).
· cites it 3× “Section 570.020(1) RSMo.1978 codifies the case law of this state that “value” of stolen property is to be determined on the basis of its market value at the time and place of the crime.”
State v. Sours, 633 S.W.2d 255 (Mo. Ct. App. 1982).
· cites it 2× “See § 570.020, RSMo 1978, for determination of value of stolen property.”
Mo. Rev. Stat. § 570.020(1): 26 cases
State v. Brown, 457 S.W.3d 772 (Mo. Ct. App. 2014).
“We agree with the defendant that section 570.020 RSMo. (Supp.2013) abrogates the rule stated in Napper, which is an example of the “continuing and vexing” valuation problems that existed prior to enactment of section 570.”
State v. Foster, 762 S.W.2d 51 (Mo. Ct. App. 1988).
“” Section 570.020(1) RSMo 1986. The state offered no evidence of the value of the items taken at the time and place of the crime.”
State v. Calicotte, 78 S.W.3d 790 (Mo. Ct. App. 2002).
“Section 570.020 defines value as “the market value of the property at the time and place of the crime.”
State v. Johnson, 461 S.W.3d 842 (Mo. Ct. App. 2015).
“Section 570.020 defines value as “the market value of the property at the time and place of the crime, or if such value cannot be satisfactorily ascertained, the cost of replacement of the property within a reasonable time after the crime.”
Woolford v. State, 58 S.W.3d 87 (Mo. Ct. App. 2001).
“…of Chapter 570, value is defined as "the market value of the property at the time and place of the crime....” Section 570.020(1).”
Mo. Rev. Stat. § 570.020(3): 2 cases
State v. Brown, 457 S.W.3d 772 (Mo. Ct. App. 2014).
“We agree with the defendant that section 570.020 RSMo. (Supp.2013) abrogates the rule stated in Napper, which is an example of the “continuing and vexing” valuation problems that existed prior to enactment of section 570.”
State v. Calicotte, 78 S.W.3d 790 (Mo. Ct. App. 2002).
“Section 570.020 defines value as “the market value of the property at the time and place of the crime.”
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