Did Missouri approve ballot wording protecting past initiatives and allowing citizens to challenge ballot titles?

Plain-English summary

Missouri Attorney General Andrew Bailey approved the legal content and form of the proposed summary statement for Jamie Howard's initiative petition 2026-058. The statement described barring legislative repeal or amendment of laws or amendments enacted by citizen initiative, including past initiatives, unless 80% of legislators referred changes to voters.

It also described prohibiting laws and legislatively referred amendments from limiting initiative or referendum powers, allowing courts to correct misleading ballot titles immediately and citizens to challenge them, requiring most measures to be decided at general elections unless 80% of legislators and the governor approved a special election, and maintaining existing vote and signature requirements. The opinion did not endorse the petition.

What this means for you

Missouri voters and initiative proponents

The reviewed statement expressly included past initiatives and described maintaining existing majority-vote and signature requirements for citizen petitions.

State legislators and election officials

The statement described an 80% referral threshold for changes and general-election placement for most measures unless the stated special-election threshold was met.

Courts, citizens, and election lawyers

The statement described allowing courts to correct misleading ballot titles immediately and permitting citizens to challenge those titles.

Common questions

Q: Did the statement apply to past initiatives?
A: Yes. It expressly included past initiatives in the described protection against legislative repeal or amendment.

Q: What threshold did the statement identify for legislative changes?
A: It described requiring 80% of legislators to refer changes to voters.

Q: Could citizens challenge ballot titles?
A: Yes. The statement described allowing courts to correct misleading titles and citizens to challenge them.

Q: What petition rules would remain?
A: Existing majority-vote and signature requirements for citizen petitions.

Background and statutory framework

The Missouri Secretary of State requested review on July 2, 2025. The attorney general reviewed the proposed summary statement under § 116.334, RSMo and approved it on July 11, 2025.

The proposal was identified as Jamie Howard's petition 2026-058. The opinion reproduced the statement's five provisions concerning initiative changes, initiative powers, ballot titles, elections, and petition requirements.

Citations and references

Statute: § 116.334, RSMo.

Source

• Landing page: https://ago.mo.gov/other-resources/ag-opinions/
• Original PDF: https://ago.mo.gov/wp-content/uploads/119-2025.pdf

Original opinion text

ATTORNEY GENERAL OF MISSOURI
ANDREW BAILEY

July 11, 2025

OPINION LETTER NO. 119-2025

The Honorable Denny Hoskins
Missouri Secretary of State
James C. Kirkpatrick State Information Center
600 West Main Street
Jefferson City, MO 65101

Dear Secretary Hoskins:

This opinion letter responds to your request dated July 2, 2025 for our review under § 116.334, RSMo of a proposed summary statement prepared for the petition submitted by Jamie Howard, 2026-058. The proposed summary statement is as follows:

Shall the Missouri Constitution be amended to:

• Bar the legislature from repealing or amending laws or amendments enacted by citizen initiative unless 80% of legislators refer changes to voters, including past initiatives;

• Prohibit laws or legislatively referred amendments from limiting initiative or referendum powers;

• Allow courts to immediately correct misleading ballot titles and permit citizens to challenge them;

• Require most ballot measures to be decided at general elections unless approved for special elections by 80%of legislators and the governor; and

• Maintain existing majority vote and signature requirements for citizen petitions?

Pursuant to § 116.334, RSMo, we approve the legal content and form of the proposed statement. Because our review of the statement is mandated by statute, no action that we take with respect to such review should be construed as an endorsement of the petition, nor as the expression of any view regarding the objectives of its proponents.

Very truly yours,

ANDREW BAILEY
Attorney General

OP-2025-131

Supreme Court Building
207 W. High Street
P.O. Box 899
Jefferson City, MO 65102
Phone: (573) 751-3321
Fax: (573) 751-0774
www.ago.mo.gov