Did Missouri approve the form of Jamie Howard's initiative petition 2026-105?

Plain-English summary

Missouri Attorney General Andrew Bailey approved Jamie Howard's initiative petition 2026-105 as sufficient as to form. The official letter identified the proposal as an amendment to Article III.

The approval was limited. Under § 116.332, RSMo, the secretary of state retained final authority to approve or reject the petition. The opinion also said that form approval did not decide substantive sufficiency or endorse the petition's objectives.

What this means for you

Initiative petition proponents

Petition 2026-105 passed the attorney general's form review under § 116.332, RSMo. The opinion did not decide whether the proposal was substantively sufficient.

Missouri election officials

The attorney general's form approval did not remove the secretary of state's final authority to approve or reject the petition.

Election lawyers and ballot-measure researchers

Opinion 164-2025 records a form-sufficiency approval for petition 2026-105 and expressly limits the effect of that approval.

Common questions

Q: Was Jamie Howard's petition 2026-105 approved as to form?
A: Yes. The attorney general approved it as sufficient as to form.

Q: Could the secretary of state still reject the petition?
A: Yes. The opinion said § 116.332 gave the secretary of state final authority to approve or reject it.

Q: Did the opinion decide whether the proposal was substantively sufficient?
A: No. The attorney general expressly declined to treat form approval as a substantive determination.

Background and statutory framework

The Missouri Secretary of State requested review on July 21, 2025. The official letter identified the proposal as an Article III amendment and as petition 2026-105.

The attorney general reviewed sufficiency as to form under § 116.332, RSMo and issued the approval on July 31, 2025. The opinion preserved the secretary of state's final approval authority.

Citations and references

Statute: § 116.332, RSMo.

Source

• Landing page: https://ago.mo.gov/other-resources/ag-opinions/
• Original PDF: https://ago.mo.gov/wp-content/uploads/164-2025.pdf

Original opinion text

ATTORNEY GENERAL OF MISSOURI
ANDREW BAILEY

July 31, 2025

OPINION LETTER NO. 164-2025

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 21, 2025 for our review under § 116.332, RSMo of the sufficiency as to form of an initiative petition to amend Article III, Revised Statutes of Missouri, submitted by Jamie Howard, 2026-105.

We approve the petition as to form, but § 116.332 gives the Secretary of State final authority to approve or reject the petition. Therefore, our approval of the form of the petition does not preclude you from rejecting the petition.

Because our review of the petition is simply for the purpose of determining sufficiency as to form, the fact that we do not reject the petition is not to be construed as a determination that the petition is sufficient as to substance. Likewise, because our review is mandated by statute, no action that we take with respect to such review should be construed as an endorsement of the petition or of the objectives of its proponents, or the expression of any view respecting the adequacy or inadequacy of the petition generally.

Very truly yours,

ANDREW BAILEY
Attorney General

OP-2025-176

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