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Missouri

UCC filings: Strong Land records: Moderate

Broad statutory UCC refusal grounds plus county clerk power to reject NCCLs What the badges mean

Last verified: July 27, 2026 — confirm current text on the official site; this date is not a promise the law is unchanged.

General information, not legal advice. Confirm current fees, forms, and deadlines on official government sites, and talk to an attorney about your situation. LienGuardAI does not file anything for you. See Legal Disclaimer & Terms of Use.
Relevant case law: A man and his sister recorded a “Notice of Claim and Proposed Lien” in the Holt County land records against two tracts, including 160 acres his brother and sister-in-law had bought from their parents’ trust. When the couple tried to get a construction loan, the title commitment showed the cloud; he refused to release it. The couple petitioned under Missouri’s nonconsensual-common-law-lien statutes. The Holt County circuit court declared the filing void from the start as a nonconsensual common-law lien and awarded costs, attorney’s fees, and statutory damages. The Western District Court of Appeals affirmed and added $1,000 in damages for a frivolous appeal. Verified. (Stiens v. Stiens, 231 S.W.3d 195 (Mo. Ct. App. 2007).)

This is a plain-language summary of a published judicial opinion, not a complete report of the case. Confirm names, holdings, and procedural posture against the opinion itself.

UCC financing statements

Check if one exists

Search Missouri's UCC records

Not free — a paid search or account is required. Login/account required. Missouri SoS requires an account for UCC searches; unauthenticated search redirects to login.

Refusal / removal authority

Missouri's §400.9-516(b)(8)–(9) and related subsections give the filing office statutory grounds to refuse materially false/fraudulent filings, debtor=secured-party / transmitting-utility / outside-scope problems, and claims against government officers, with an inmate-filer presumption and a Secretary of State wrongful-filing termination path in (e).

Citations MO §400.9-516 MO §400.9-516
Full citations
  • Mo. Rev. Stat. §400.9-516(b)(8),(b)(9)
  • Mo. Rev. Stat. §400.9-516(e)

The filing office refuses at filing on the statutory triggers; inmate presumption can be rebutted with a sworn statement. SoS may terminate wrongfully filed records under (e).

If it's already filed: §400.9-516(e) SoS termination; NCCL chapter §428.110–.135; information statement / §625 remedies.

Real-property liens

Missouri's §428.110 lets a clerk reject a nonconsensual common-law lien (with listed carve-outs) and provides immunity for acceptance or rejection. Owners petition to nullify under §428.120 (not §428.115 — that section is the rejected claimant's petition to force filing).

Citations MO §428.110 MO §428.120
Full citations
  • Mo. Rev. Stat. §428.110
  • Mo. Rev. Stat. §428.120

Clerk may reject an NCCL; notice of invalid lien procedures apply; owner files a §428.120 petition (ex parte timing rules in the chapter).

If it's already recorded: §428.120 petition; related civil/criminal tools in chapter 428 / §575.133.

Real-property records are held by the recorder of deeds where the property sits.

Get notified before it happens

A free "property fraud alert" service is available in at least part of Missouri — it emails or mails you whenever a document gets recorded against your name, so you find out right away instead of months later. Sign up for St. Louis County Property Fraud Alert →

Missouri's largest county. No statewide mandate.

If the path runs through court

Missouri doesn't have a self-filed administrative form for this — the verified remedy runs through a court, which generally means an attorney rather than a fill-in-the-blank document.

Petition to Nullify a Nonconsensual Common-Law Lien

Missouri's recorder of deeds can already reject a nonconsensual common-law lien (NCCL) at the counter under §428.110 — but if one is recorded anyway, the owner's tool is a §428.120 petition to nullify, which comes with ex parte timing rules built into the chapter. Which statute: §428.115 is a different provision — the rejected claimant's petition to force filing — not something an owner uses to clear their own title.

This generally requires an attorney. The nullify petition is an ex parte court filing with specific statutory timing, and confusing it with the claimant-side §428.115 petition would point you at the wrong process entirely — worth having counsel get this right.
Citation MO §428.120

People consulting an attorney about a filing like this often bring:

  • A copy of the filing, if available, and where and when it was filed or recorded (office, date, and document or instrument number)
  • Any notices, letters, or other correspondence about it
  • Records for the property or account it names, such as a deed, title, or loan papers
  • Notes on any contact with the filer or the filing office, with dates
  • This page's citations and their check dates

How this usually works in Missouri

A summary of the tools Missouri law and filing offices provide — general information, not instructions for your facts. Confirm current practice with the filing office and talk to an attorney about your situation.

  1. 1Missouri UCC search requires an account (a paid path) through the Secretary of State's business services portal.
  2. 2§400.9-516 lets the filing office refuse filings matching its fraud, debtor-as-secured-party, or government-officer triggers, and (e) provides a termination path.
  3. 3For a nonconsensual common-law lien on land, §428.110 provides recorder rejection, and §428.120 provides a court order to clear title.
  4. 4§428.115 is a petition for a rejected lien claimant, not an owner cleanup tool.

What to expect

Missouri is one of the stronger dual-pathway states; the owner petition is under §428.120. Confirm the current fee on the state's official site — filing and search fees change and are not published here.

Sources: the LienGuardAI fifty-state survey and UCC search portal review (How we verify). No dollar fee amounts are published here — always confirm the current fee on the state's own site.