The Missouri law of easements might not be the place one would expect to find a progressive development of the law. Over the past four decades, some courts have begun to shake up Missouri's approach to relocation of easements, while still paying lip service to the old rules. Although Missouri courts have neither openly nor uniformly recognized the new approach, it nonetheless guides some courts' decisions. With a few distinctions, Missouri courts have experimented with what amounts to adoption of the Restatement (Third) of the Law of Property's progressive stance.' An examination of Umphres reveals this modem approach to a servient estate holder's right to relocate an easement, and may provide a glimpse of things to come in Missouri easement law.
Douglas B. Harris,
Balancing the Equities: Is Missouri Adopting a Progressive Rule for Relocation of Easements,
61 Mo. L. Rev.
Available at: https://scholarship.law.missouri.edu/mlr/vol61/iss4/7