Missouri Implied Warranty of Habitability and Repair-and-Deduct

Missouri's implied warranty of habitability comes from case law, not statute. In Detling v. Edelbrock, 671 S.W.2d 265 (Mo. banc 1984), the Missouri Supreme Court held a landlord impliedly warrants residential premises are habitable at lease inception and remain so during the term. The statutory repair-and-deduct remedy is RSMo 441.234: a tenant who has lawfully occupied the unit for six consecutive months, is current on rent, and has no uncured violations may, after written notice and a 14-day cure period, fix a defect that violates a local housing or building code and "detrimentally affects habitability, sanitation or security." The deductible cost is "less than three hundred dollars, or one-half of the periodic rent, whichever is greater," never exceeding one month's rent, with a one-month-rent aggregate cap per twelve months.

No fixed statutory fine. A landlord who breaches the warranty of habitability may face damages, rent abatement, or a constructive-eviction defense; the repair-and-deduct statute lets the tenant offset qualifying repair costs against rent within the dollar caps.