MO Opinion No. 328-2025 October 29, 2025

What fiscal impact did Missouri approve for Richard von Glahn's House Bill 1 referendum petition 2026-R004?

Short answer: The Attorney General approved the legal content and form of the fiscal note summary for referendum petition 2026-R004. The approved summary said state and local governmental entities estimated no costs or savings, but the review did not assess whether the estimate was fair or sufficient.

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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 AG opinions are persuasive authority but not binding precedent.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.

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Plain-English summary

Missouri Attorney General Catherine L. Hanaway approved the legal content and form of the fiscal note summary for Richard von Glahn's referendum petition 2026-R004 on House Bill No. 1.

The approved summary stated: "State and local governmental entities estimate no costs or savings." The opinion said review under § 116.175.4, RSMo did not examine the fairness or sufficiency of that estimated fiscal impact and should not be read as an endorsement.

What this means for you

Referendum proponents

The fiscal note summary for referendum petition 2026-R004 passed legal-content and form review. The opinion did not endorse the referendum.

State and local government researchers

Opinion 328-2025 records a no-cost, no-savings estimate and expressly limits the Attorney General's review of that estimate.

Missouri State Auditor staff

The submitted fiscal note summary was approved in the form presented.

Common questions

Q: What fiscal impact did the summary report?
A: State and local governmental entities estimated no costs or savings.

Q: Did the Attorney General decide that estimate was fair or sufficient?
A: No. The opinion expressly said the review did not examine fairness or sufficiency.

Q: Did approval endorse the referendum?
A: No. The opinion disclaimed endorsement.

Background and statutory framework

The State Auditor submitted the fiscal note and summary on October 17, 2025 for Richard von Glahn's referendum petition 2026-R004.

The Attorney General issued Opinion 328-2025 on October 29, 2025 and approved the summary's legal content and form under § 116.175.4, RSMo.

Citations and references

Statutes: § 116.175, RSMo; § 116.175.4, RSMo.

Source

Landing page: https://ago.mo.gov/other-resources/ag-opinions/
Original PDF: https://ago.mo.gov/wp-content/uploads/328-2025.pdf

Original opinion text

ATTORNEY GENERAL OF MISSOURI
CATHERINE L. HANAWAY

October 29, 2025

OPINION LETTER NO. 328-2025

The Honorable Scott Fitzpatrick
Missouri State Auditor
Truman State Office Building, Room 880
Jefferson City, MO 65101

Dear Auditor Fitzpatrick:

This office received your letter of October 17, 2025, submitting a fiscal note and fiscal note summary prepared under § 116.175, RSMo, for a referendum petition submitted by Richard von Glahn (2026-R004). The fiscal note summary that you submitted is as follows:

State and local governmental entities estimate no costs or savings

Under § 116.175.4, RSMo, we approve the legal content and form of the fiscal note summary. Because our review of the fiscal note summary is mandated by statute, no action that we take with respect to such review should be construed as an endorsement of the initiative petition or as the expression of any view regarding the objectives of its proponents. Furthermore, our review under § 116.175.4 does not examine the fairness or sufficiency of the estimated fiscal impact.

Very truly yours,

CATHERINE L. HANAWAY
Attorney General

OP-2025-349

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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