Missouri Revised Statutes

Mo. Rev. Stat. § 621.145 (2026)

Judicial review

✓ current as of May 2026
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  621.145.  Judicial review. — Except as otherwise provided by law, all final decisions of the administrative hearing commission shall be subject to judicial review as provided in and subject to the provisions of sections 536.100 to 536.140, except that in cases where a disciplinary order may be entered by the agency, no decision of the administrative hearing commission shall be deemed final until such order is entered.  For purposes of review, the action of the commission and the order, if any, of the agency shall be treated as one decision.  The right to judicial review as provided herein shall also be available to administrative agencies aggrieved by a final decision of the administrative hearing commission.

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(L. 1965 p. 277 § 9, A.L. 1978 S.B. 661)

Notes of Decisions
Cited in 41 cases (2 in the last 5 years), 1985–2024 · leading case: Missouri Health Facilities Review Comm. v. Admin. Hearing Comm'n, 700 S.W.2d 445 (Mo. 1985).
Missouri Health Facilities Review Comm. v. Admin. Hearing Comm'n, 700 S.W.2d 445 (Mo. 1985). · cites it 6× “1984, which reads as follows: Except as otherwise provided by law, all final decisions of the administrative hearing commission shall be subject to judicial review as provided in and subject to the provisions of sections 536.”
Kerwin v. Missouri Dental Bd., 375 S.W.3d 219 (Mo. Ct. App. 2012). · cites it 4× ““In such a case, section 621.145 directs that we review the 'AHC’s decision as to the existence of cause and the Board’s subsequent disciplinary order “as one decision,” and proceed to review that combined decision, not the circuit court’s judgment.”
Johnson v. Missouri Bd. of Nursing Administrators, 130 S.W.3d 619 (Mo. Ct. App. 2004). · cites it 2× “7 In August 2002, as authorized by § 621.145, Johnson then sought judicial review of the AHC’s decision and the Board’s order in the Circuit Court of Cole County.”
Karen Carpenter v. State Bd. of Nursing, 508 S.W.3d 110 (Mo. 2016). · cites it 4× “Section 621.145, however, requires this Court to treat the AHC hearing and the Board’s disciplinary hearing as a single administrative proceeding.”
Dorman v. State Bd. of Reg. for the Healing Arts, 62 S.W.3d 446 (Mo. Ct. App. 2001). · cites it 2× “” Section 621.145. 3 The Commission’s decision “is presumed valid, and the burden is on the attacking party to overcome that presumption.”
Bodenhausen v. Missouri Bd. of Reg. for the Healing Arts, 900 S.W.2d 621 (Mo. 1995). · cites it 2× “§§ 621.145 & 536.100: Final disciplinary actions are available to the public.”
Asbury v. Lombardi, 846 S.W.2d 196 (Mo. 1993). “— and from thence, judicial review under §§ 621.145 and 536.100 to 536.-140. Id. at 864.”
Moore v. Missouri Dental Bd., 311 S.W.3d 298 (Mo. Ct. App. 2010). · cites it 2× “In such a case, section 621.145 directs that we review the “AHC’s decision as to the existence of cause and the Board’s subsequent disciplinary order ‘as one decision,’ and proceed to review that combined decision, not the *303 circuit court’s judgment.”
Lederer v. State, Dep't of Soc. Servs., Div. of Aging, 825 S.W.2d 858 (Mo. Ct. App. 1992). · cites it 2× “See § 621.145; § 536.110. In the absence of a provision by law for judicial review of an adjudication of the AHC under § 36.”
Health Servs. Mgmt., Inc. v. Missouri Health Facilities Review Comm., 791 S.W.2d 732 (Mo. Ct. App. 1990). · cites it 4× “335 incorporates § 621.145. Missouri Health Facilities Review Comm.”
State Ex Rel. Missouri State Bd. of Pharmacy v. Admin. Hearing Comm'n, 220 S.W.3d 822 (Mo. Ct. App. 2007). · cites it 4× “Section 621.145 provides that “all final decisions of the administrative hearing commission shall be subject to judicial review as provided in and subject to the provisions of sections 536.”
Wells v. Dir. of Pub. Saf., 295 S.W.3d 597 (Mo. Ct. App. 2009). · cites it 4× “This case involved an AHC decision and a subsequent disciplinary order by the Director.”
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