Missouri Law Update — October 2025

Missouri's Backyard Chicken Law Was Ruled Unconstitutional. Here's What That Means for Flock Owners.

In October 2025, a Cole County Circuit Court judge struck down HB 2062 — Missouri's 2024 law that allowed up to 6 hens and overrode HOA bans. The ruling is being appealed. If you have chickens in Missouri, here's what you need to know right now.

ACTIVE — Ruling stands as of November 2025, state appeal pending
Direct answer: Missouri's HB 2062 — which protected flock owners from HOA chicken bans and guaranteed up to 6 hens on qualifying lots — was ruled unconstitutional in October 2025. The ruling stands while under appeal. Missouri HOAs can now enforce chicken bans again. City ordinances (Kansas City, St. Louis, Columbia, etc.) still permit chickens independently.

Missouri passed House Bill 2062 in 2024 with broad support. The law was relatively simple: it allowed residents on lots of at least 0.2 acres to keep up to 6 hens, and it overrode HOA CC&Rs that banned them. For Missouri's growing population of urban and suburban flock owners, it looked like a decisive victory.

Then, in October 2025, a Cole County Circuit Court judge ruled the entire bill unconstitutional — not because of the chicken provisions themselves, but because of how the bill was constructed under Missouri's constitutional requirements for single-subject legislation. The HOA-override provision, combined with unrelated elements in the bill, created a constitutional problem. The judge threw out the whole law.

The state has appealed. As of this writing, the appeal is pending at the Missouri Court of Appeals Western District. The ruling stands in the meantime.

What Was HB 2062?

Missouri House Bill 2062, passed in 2024, did three things relevant to backyard flock owners:

  1. Established a statewide baseline allowing residents on lots of 0.2 acres or more to keep up to 6 hens.
  2. Explicitly prohibited HOA CC&Rs from banning chickens on qualifying lots.
  3. Made clear that local municipalities could still regulate (but not prohibit outright) chicken-keeping consistent with the state baseline.

For the roughly 60+ percent of Missouri's HOA residents who previously had blanket chicken bans in their CC&Rs, the bill was transformative. Many residents began acquiring hens in 2024 relying on its protections.

Why Was It Struck Down?

Missouri's Constitution, Article III, Section 23, requires that every bill contain only one subject, clearly expressed in its title. The Cole County Circuit Court found that HB 2062 violated this single-subject rule by bundling the chicken provisions together with unrelated regulatory matters. The court did not rule on whether the chicken policy itself was good or bad — only that the legislative packaging was unconstitutional.

This type of ruling is more common than it sounds. Missouri courts have struck down laws on single-subject grounds before. The fix — if the state legislature wants to pass a similar law — is to reintroduce the chicken provisions cleanly in a standalone bill with a title that clearly covers only that subject.

What This Is Not

The ruling is not a statement that backyard chickens are illegal in Missouri. It simply means the 2024 law that protected them from HOA bans no longer exists. Local city ordinances that permitted chickens still permit them. The change is to HOA authority: HOAs can now enforce their chicken bans again.

What Does This Mean If You Already Have Chickens?

This depends on where you live. There are three situations:

You live outside an HOA (no CC&Rs)

The ruling has minimal effect on you. Your rights depend on your city or county ordinance, not on HB 2062. If your city permits chickens, you're still fine. If your city prohibits them, you were already in violation regardless of HB 2062.

You live in an HOA that previously banned chickens and you got chickens after HB 2062 passed

This is the most difficult situation. With HB 2062 gone, your HOA's original CC&R ban is back in effect. Your HOA could resume enforcement — including fines — for chickens acquired during the period when you believed the law protected you. Some HOAs may choose not to enforce against existing flocks; others may not. You should consult a Missouri HOA attorney if you receive a notice.

You live in an HOA that updated its CC&Rs to allow chickens after HB 2062

If your HOA formally amended its CC&Rs during 2024 to permit chickens — and that amendment was properly recorded — those amended CC&Rs remain in effect. The ruling doesn't un-amend HOA documents that were voluntarily changed. Check your HOA's recorded documents to see what version of the CC&Rs governs your community.

What Missouri Flock Owners Should Do Now

  1. Check your city's ordinance first. Many Missouri cities — including Kansas City, St. Louis, Columbia, and Springfield — have their own ordinances permitting backyard chickens. Your city's code governs regardless of HB 2062.
  2. Pull your HOA's current CC&Rs. Get the most recently recorded version from your county recorder's office (or your HOA management company). Read what they say about livestock or poultry.
  3. Don't assume your HOA won't enforce. Even if they've been quiet, the ruling restores their legal authority. If you're in violation under the restored CC&Rs, that violation exists whether or not the HOA has sent a notice.
  4. Monitor the appeal. If Missouri's Court of Appeals reverses the circuit court, HB 2062 would be reinstated. This is not a resolved situation — it's actively in progress.
  5. Contact your state representative. If you want this law reinstated, the legislature can pass a clean single-subject bill with the same provisions. Constituent calls and emails drive that kind of reintroduction.

Missouri Cities With Their Own Ordinances (Still In Effect)

City Chickens Permitted? Max Hens Permit Required? Roosters?
Kansas CityYes4 hensYesNo
St. Louis (city)Yes6 hensYesNo
ColumbiaYes6 hensNoNo
SpringfieldYesLot-size basedYesNo
Jefferson CityRestrictedVaries by zoneCheckNo
JoplinYes6 hensNoNo
St. CharlesRestrictedVaries by zoneCheckNo
IndependenceYes6 hensYesNo

Always verify current rules directly with your city. Ordinances are updated periodically and this table reflects publicly available information as of late 2025.

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Frequently Asked Questions

If the appeal succeeds, does HB 2062 automatically come back into effect?
If Missouri's Court of Appeals reverses the circuit court ruling, HB 2062 would be reinstated and HOA bans on chickens would again be unenforceable for qualifying lots. The appeal timeline is uncertain — Missouri appellate cases typically take 12–24 months to resolve.
Can my HOA retroactively fine me for chickens I had during HB 2062's brief period?
This is a legal gray area. You acted in good faith under a law that was on the books. However, the circuit court treated the law as void from the beginning — not just going forward. Whether that exposes you to retroactive HOA fines is a fact-specific question for a Missouri attorney. Many HOAs will not pursue retroactive enforcement, but some may.
Does the ruling affect urban farming or garden rights in Missouri beyond chickens?
HB 2062 contained some provisions related to vegetable gardens and urban agriculture in addition to the chicken provisions. All of those provisions were struck down as part of the same ruling. The single-subject constitutional problem affected the entire bill.
What is the fastest path to getting chicken protections reinstated in Missouri?
The fastest path is for the Missouri General Assembly to pass a clean, single-subject bill covering only backyard chicken rules — with a title that makes the subject clear. This avoids the constitutional defect that brought down HB 2062. Constituent pressure on state representatives is the primary lever here.
My city allows chickens but my HOA says I can't have them after the ruling. Who wins?
In Missouri right now, your HOA's CC&Rs govern your private property use within the HOA. A city ordinance that permits chickens doesn't override your HOA's private covenant. The city permission sets a floor (the city won't penalize you), but your HOA can set a stricter standard through contract. Without HB 2062, there is currently no Missouri state law preventing that.
Informational Only. This page summarizes publicly available information about Missouri HB 2062 and the 2025 circuit court ruling for general reference purposes. It is not legal advice. The legal situation is actively evolving — consult a licensed Missouri attorney for advice about your specific circumstances.
Related: Missouri State Guide · Kansas City, MO · HOA Rights by State · Florida HOA Law (contrast)