Rule 71.02.Jury Shall Render General Verdict--When.

Part I · Rule 71: Verdicts · Not amended since adoption on record · Last verified July 22, 2026

In one sentenceRule 71.02 requires the jury to render a general verdict in every case seeking only the recovery of money or specific real or personal property.

Full Text of Rule 71.02

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In every issue for the recovery of money only, or specific real or personal property, the jury shall render a general verdict.

Official Comment

This Rule is the same as Section 107 of the 1943 Code ( Section 510.230, RSMo 1959). This rule is the same as original proposed Rule 22.02(a). Paragraph (b) of the proposed Rule 22.02 provided for a discretionary special verdict in the form of special findings on each issue of fact, and for submission to a jury of special interrogatories. Paragraph (b) is omitted for these reasons: (1) it is a radical change in the existing practice; (2) experience with similar provisions has not been uniformly satisfactory; (3) the Bar overwhelmingly opposed the discretionary special verdict system in all cases. Compare: Rule 49, Federal Rules of Civil Procedure.

Plain-English Summary

Rule 71.02 narrows the choice between general and special verdicts for a whole category of cases. Wherever the issue is the recovery of money only, or of specific real or personal property, the jury must render a general verdict — the special-verdict alternative described in Rule 71.01 isn't on the table for these claims.

This requirement channels the most common civil claims — those seeking damages or the return of particular property — into the general-verdict format, where the jury decides for the plaintiff or defendant instead of confining itself to fact-finding alone.

Frequently Asked Questions

When must a jury return a general verdict instead of a special verdict?

In every case for the recovery of money only, or of specific real or personal property.

Does this rule allow the parties to request a special verdict instead in a money-damages case?

No, the rule requires a general verdict in that category of case.

What kinds of claims trigger the general-verdict requirement?

Claims for the recovery of money only, or for specific real or personal property.

Does this rule apply to bench trials?

The rule speaks to what the jury renders, so it applies to cases tried to a jury on those kinds of claims.

How does this rule relate to Rule 71.06?

Rule 71.06 builds on the general-verdict requirement here by specifying that the jury must also assess the amount of recovery when it finds for the plaintiff in a money-only case.

Source & verification. Rule text and amendment history are reproduced verbatim from the Missouri State & Federal Court Rules, adopted by the Supreme Court of Missouri. Last verified July 22, 2026. · Official source

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