Ladybird Deeds in Missouri

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Counsel is correct that this is a “Ladybird Deed”, but the problem is that its recognition in MO is based on a case from 1953. It hasn’t been overturned by the courts or eliminated by statute, but I wouldn’t say it’s been enthusiastically affirmed by the courts either since then. Without a statute, we always have the risk that a court may decide they no longer likes a previous decision or may decide to introduce a new nuance that it previously didn’t recognize.