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MO Opinion No. 308-2025 October 6, 2025

What ballot summary did Missouri approve for petition 2026-126 requiring Ten Commandments displays in public-school classrooms?

Short answer: The Attorney General approved the legal content and form of the ballot summary for petition 2026-126. The summary described required Ten Commandments displays in public elementary and secondary classrooms, state display rules, possible public or private funding, other accompanying documents, and a declaration that the displays were not an establishment of religion.

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This page answers the general question as of 2025. Ezel answers yours: what it means for your facts, under current Missouri law, with citations.

Disclaimer: This is an official Missouri Attorney General opinion. AG opinions are persuasive authority but not binding precedent. This summary is for informational purposes only and is not legal advice. Consult a licensed Missouri attorney for advice on your specific situation.
About this page: The plain-English summary, reader guidance, and Q&A below were written by Ezel based on the official AG opinion. The original opinion (linked on this page as a PDF) is the authoritative source for any reliance.
View original AG opinion (PDF)

Plain-English summary

Missouri Attorney General Catherine L. Hanaway approved the legal content and form of the proposed ballot summary for Mark Johnson's initiative petition 2026-126, an Article IX amendment concerning Ten Commandments displays in public schools.

The approved summary described four features. It would require every public elementary and secondary school classroom to display a durable copy of the Ten Commandments measuring at least 11 by 17 inches. It would authorize the Department of Elementary and Secondary Education to set rules for uniformity, placement, and maintenance and permit public funds or private donations. It would allow other historical or civic documents beside the display. It would also specify that the displays were not an establishment of religion.

The Attorney General's review under § 116.334, RSMo was limited to the summary's legal content and form. The opinion did not endorse the petition or express a view about its objectives.

What this means for you

Initiative petition proponents

The proposed summary for petition 2026-126 passed the Attorney General's legal-content and form review. The opinion did not decide the proposal's merits.

School district officials

The approved wording described a proposed constitutional mandate for classroom displays and proposed rulemaking authority for the Department of Elementary and Secondary Education. The opinion itself did not enact those requirements.

Voters and ballot-measure researchers

Opinion 308-2025 records the exact four-part summary approved for this Article IX proposal, including display size, funding, accompanying documents, and the establishment-of-religion statement.

Common questions

Q: What classrooms did the proposal cover?
A: The approved summary said each public elementary and secondary school classroom.

Q: What size display did the summary specify?
A: A durable copy at least 11 by 17 inches.

Q: Could public money be used for the displays?
A: The approved summary said the proposal would permit public funds or private donations.

Q: Did the Attorney General decide whether the proposal was constitutional?
A: The opinion approved only the summary's legal content and form under § 116.334 and expressly disclaimed endorsement of the proposal.

Background and statutory framework

The Secretary of State requested review on September 26, 2025. The proposed summary concerned Mark Johnson's petition 2026-126 to amend Article IX of the Missouri Constitution.

The Attorney General issued Opinion 308-2025 on October 6, 2025 and approved the summary's legal content and form under § 116.334, RSMo.

Citations and references

Statute: § 116.334, RSMo.

Source

Original opinion text

ATTORNEY GENERAL OF MISSOURI
CATHERINE L. HANAWAY

October 6, 2025

OPINION LETTER NO. 308-2025

The Honorable Denny Hoskins, CPA
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 September 26, 2025, for our review under § 116.334, RSMo, of a proposed summary statement prepared for the petition submitted by Mark Johnson (2026-126) regarding a proposed constitutional amendment to amend Article IX of the Missouri Constitution. The proposed summary statement is as follows:

Shall the Missouri Constitution be amended to:

  • require each public elementary and secondary school classroom to display a durable copy of the Ten Commandments, at least 11 by 17 inches in size;
  • authorize the Department of Elementary and Secondary Education to set rules for uniformity, placement, and maintenance of displays, and permit use of public funds or private donations;
  • allow display of other historical or civic documents alongside the Ten Commandments; and
  • specify that such displays shall not be considered an establishment of religion?

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,

CATHERINE L. HANAWAY
Attorney General

OP-2025-328

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

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