Rule 55.11.Averments, How Made.
Part I · Rule 55: Pleadings, Motions and Hearing · Last amended September 1, 1973 · Last verified July 22, 2026
Full Text of Rule 55.11
Amendment History
Adopted Jan. 19, 1973, eff. Sept. 1, 1973.
Official Comment
This is the same as prior Rule 55.13. Compare: Rule 10(b) of the Federal Rules of Civil Procedure.
Plain-English Summary
Every averment of a claim or defense goes into a numbered paragraph, and each paragraph should be limited, as far as practicable, to a single set of circumstances. Numbering matters because it lets later pleadings reference an earlier paragraph by number instead of restating it, keeping the case file easier to track across rounds of pleading.
The rule also calls for separation at a higher level: each claim founded on a separate transaction or occurrence, and each defense other than a plain denial, should get its own count or defense whenever separating them makes the case clearer. It’s a flexibility standard instead of a rigid rule — separation is required when it facilitates clear presentation, not in every conceivable case.
Frequently Asked Questions
Do Missouri pleadings need numbered paragraphs?
Yes. Rule 55.11 requires averments to be stated in numbered paragraphs, each limited so far as practicable to a single set of circumstances.
Can I reference a paragraph number from an earlier pleading?
Yes, the rule specifically allows referring to a paragraph by number in later pleadings.
When must I use separate counts for different claims?
Whenever separation facilitates the clear presentation of the matters, particularly for claims founded on separate transactions or occurrences.
Do defenses need to be stated in separate counts too?
Yes, each defense other than a denial should be separately stated when doing so aids clarity.
What’s the purpose of numbered paragraphs under this rule?
To organize the pleading around discrete factual circumstances and make it easy to reference specific averments later in the case.