When Missouri courts determine the existence of a cause of action under the wrongful death statute they have considered it necessary to address whether a fetus is a "person" within the statute. In Connor v. Monkem, Missouri extended its recognition of the rights of a fetus within its wrongful death statute beyond its previous decisions and those noted in other jurisdictions. Missouri’s decision differs distinctively from the law’s traditional view of the fetus as a part of the woman, therefore devoid of rights as a separate entity.

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