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Lady Bird Deeds in Missouri

Short answer: yes, under another name. Missouri's courts have long recognized the life estate deed with powers, which works like a lady bird deed. Deedly does not prepare one yet. Here is what the law says and what we prepare instead.

Reviewed September 1, 2026
Create my Missouri beneficiary deed

Missouri recognizes this deed as the life estate deed with powers

Missouri does not use the name "lady bird deed", but its law has long recognized the same idea under another name. Deedly does not prepare a life estate deed with powers yet. The deed below is the one we do prepare for the same goal.

How Missouri law treats the life estate deed with powers

Missouri has no lady bird deed statute, but its Supreme Court has upheld a deed in which the owner conveyed a home and reserved a life estate "with power to sell, rent, lease, mortgage or otherwise dispose of said property" for life. The court held that the reserved powers, which amounted to a power to revoke, did not make the deed an invalid will, and when the owner died without using them the grantee owned the property outright. Deedly does not prepare that deed. Missouri's statutory beneficiary deed (Mo. Rev. Stat. § 461.025) does the same job more simply: you keep full control, and the property passes outside probate.

The leading decisions: St. Louis County Nat'l Bank v. Fielder, 364 Mo. 207, 260 S.W.2d 483 (Mo. banc 1953).

Why the exact wording matters

The court upheld the deed because it conveyed title at once and reserved only a life estate with powers. It noted that every Missouri deed it had found to be an invalid will said that title would not pass until the owner's death. The wording decides which side of that line a deed falls on.

What Deedly prepares in Missouri instead

Create my Missouri beneficiary deed

$49, one time. The probate-avoidance deed Missouri does recognize, with the state's witness rules, margins, and recording instructions already applied. You read the finished document before you pay.

Common questions

Yes, as a life estate deed with powers. Missouri has no lady bird deed statute, but its Supreme Court has upheld a deed in which the owner conveyed a home and reserved a life estate "with power to sell, rent, lease, mortgage or otherwise dispose of said property" for life. The court held that the reserved powers, which amounted to a power to revoke, did not make the deed an invalid will, and when the owner died without using them the grantee owned the property outright. Deedly does not prepare that deed. Missouri's statutory beneficiary deed (Mo. Rev. Stat. § 461.025) does the same job more simply: you keep full control, and the property passes outside probate.

Deedly only prepares an instrument after checking its wording, filing steps, and tax treatment against that state's law. That review is not finished for Missouri's life estate deed with powers. No statute prescribes its wording, and the courts hold the owner to the exact words used, so the wording decides what powers you keep. It is worth getting right. In the meantime, the Missouri beneficiary deed does the same job and Deedly prepares it.

Florida, Michigan, Rhode Island, Texas, Vermont, and West Virginia have them by statute or settled practice. Maryland's courts also recognize a similar instrument, the life estate deed with powers. Missouri's courts also recognize a similar instrument, the life estate deed with powers. Virginia law also recognizes a similar instrument, the life estate deed with powers.

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Deedly is not a law firm

Its software and documents are not a substitute for the advice of an attorney. We provide self-help software and state-specific deed forms; you make your own decisions about your property. Using Deedly does not create an attorney-client relationship, and nothing here is legal advice. If your situation is complex or contested, talk to a licensed attorney in your state.