Missouri Revised Statutes

Mo. Rev. Stat. § 84.330 (2026)

Police force members are officers of state

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  84.330.  Police force members are officers of state. — The members of the police force of the cities covered by sections 84.010 to 84.340, organized and appointed by the police commissioners of said cities, are hereby declared to be officers of the said cities, under the charter and ordinances thereof, and also to be officers of the state of Missouri, and shall be so deemed and taken in all courts having jurisdiction of offenses against the laws of this state or the ordinances of said cities.

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(RSMo 1939 § 7711)

Prior revisions: 1929 § 7563; 1919 § 8973; 1909 § 9825

Notes of Decisions
Cited in 13 cases (3 in the last 5 years), 1953–2025 · leading case: Hodges v. City of St. Louis, 217 S.W.3d 278 (Mo. 2007).
Hodges v. City of St. Louis, 217 S.W.3d 278 (Mo. 2007). · cites it 28× “Louis and Kansas City, section 84.330 states: The members of the police force of the cities covered by sections 84.”
Smith v. State, 152 S.W.3d 275 (Mo. 2005). · cites it 4× “Although the status of the Board as an agency of the state under the SLEF is based on a structural analysis of the statutes creating the Board and analogies to case law holding that the Board is an agency of the state in other contexts, the police officers' status as "officers…”
State ex rel. Sayad v. Zych, 642 S.W.2d 907 (Mo. 1982). · cites it 4× “Fourth, § 84.330, RSMo 1978, states that police force members are officers of the state as well as of the city.”
Stemmler v. Einstein, 297 S.W.2d 467 (Mo. 1957). · cites it 6× “In Section 84.330 RSMo 1949, V.A.M.S., it is clearly provided that: "The members of the police force of the cities covered by sections 84.”
State ex rel. Hawley v. City of St. Louis, 531 S.W.3d 602 (Mo. Ct. App. 2017). “the state legal expense fund shall not be available for the payment of any claim or any amount required by any final judgment rendered by a court of competent jurisdiction against a board of police commissioners established under chapter 84, including the commissioners, any…”
Frank v. Wabash R.R. Co., 295 S.W.2d 16 (Mo. 1956). · cites it 2× “325, the issue in this case is narrowed to the question of whether Gil-lispie possessed the authority of a police officer to arrest plaintiff for the commission of a misdemeanor in his presence. At the time of the arrest, Gillispie held a valid license as a private watchman…”
State ex rel. Priest v. Gunn, 326 S.W.2d 314 (Mo. 1959). · cites it 2× “And section 84.330 declares that the members of the police force (not the “clerks and subordinates”) of St.”
Sherf v. Koster, 371 S.W.3d 903 (Mo. Ct. App. 2012). “3 4 was added at that time and states: Moneys in the state legal expense fund shall not be available for the payment of any claim or any amount required by any final judgment rendered by a court of competent jurisdiction against a board of police commissioners established under…”
Barnard v. Wabash R. Co, 208 F.2d 489 (8th Cir. 1953). “” Section 84.330 RSMo 1949, V.A.M.S., further provides: “The members of the police force of the cities covered by sections 84.”
Banks v. Slay, 9 F. Supp. 3d 1069 (E.D. Mo. 2014). · cites it 2× “Therefore, although the SLMPD police officers were, and continue to be, officers of the State and the City, Mo.Rev. Stat. § 84.330, "this dual status d[id] not mean the City [wa]s a proper defendant in a § 1983 case challenging City police officers’ conduct against an individual.”
Michael Holmes v. Sarah Steelman, 624 S.W.3d 144 (Mo. 2021). · cites it 3× “726 to add subsection 3, which provided: Moneys in the state legal expense fund shall not be available for the payment of any claim or any amount required by any final judgment rendered by a court of competent jurisdiction against a board of police commissioners established…”
Lisa Wilson v. Attorney Gen. & Comm'r of Admin., No. WD83784 (Mo. Ct. App. Mar. 9, 2021). “Moneys in the state legal expense fund shall not be available for the payment of any claim or any amount required by any final judgment rendered by a court of competent jurisdiction against a board of police commissioners established under chapter 84, RSMo, including the…”
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