It would seem that from the very outset the Supreme Court of Missouri refused to accept the common law as to larceny of choses in action. In State v. Newell there was an indictment for obtaining bills of exchange by false pretenses.
Kenneth C. Sears,
Larceny of Referendum Petitions (concluded),
22 Bulletin Law Series.
Available at: https://scholarship.law.missouri.edu/ls/vol22/iss1/3