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DRAFT FOR ATTORNEY REVIEW — NOT FINAL

Kohner Props., Inc. v. Johnson, 553 S.W.3d 280 (2018)

Citation
Kohner Props., Inc. v. Johnson, 553 S.W.3d 280 (2018)
Parent Document
Kohner Props., Inc. v. Johnson, 553 S.W.3d 280 (2018)
Jurisdiction
Missouri (state)
Effective Date
2018-07-03

Other Sections in This Document (45)

Full Text

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Even if King 's pronouncement of an in custodia legis procedure was dicta , it is undisputed that the legal pronouncement in King has been dutifully followed by our circuit courts for almost five decades in the absence of contrary guidance from this Court or the Missouri General Assembly. See, e.g. , 36 Jane Pansing Brown, Missouri Practice Series: Landlord-Tenant Handbook §§ 1:1, 23:8 (2017); 18A Timothy J. Tryniecki, Missouri Practice Series: Real Estate Law § 52:18 (3d ed. 2006). Moreover, since King , the in custodia legis procedure has been discussed in at least two reported decisions by the court of appeals: Tower Management, Inc. v. Henry , 687 S.W.2d 564 (Mo. App. W.D. 1984), and Wulff v. Washington , 631 S.W.2d 109 (Mo. App. W.D. 1982). As in King , however, the tenant in Wulff vacated the premises, 631 S.W.2d at 109-10, and, therefore, any discussion of an in custodia legis procedure in Wulff is, likewise, dicta. And in Henry , the tenants retained possession, but did not deposit their rent to the circuit court in custodia legis. 687 S.W.2d at 565-66.2