Did Missouri approve the form of Jamie Howard's initiative petition 2026-014?

Plain-English summary

Missouri Attorney General Andrew Bailey approved Jamie Howard's initiative petition 2026-014 as to form. The petition proposed an amendment to Article III of the Missouri Constitution.

The approval was limited. The opinion said the secretary of state had final authority to approve or reject the petition, and it did not determine whether the petition was sufficient as to substance or endorse the proposal.

The official 2024 archive labels Opinion 43-2024 as a rejection, but the linked official PDF says, "We approve the petition as to form." This page follows the opinion text while preserving the archive's title in the source metadata.

What this means for you

Initiative petition proponents

Petition 2026-014 passed the attorney general's form review. The opinion did not decide whether the proposal was substantively sufficient or express a view about its objectives.

Missouri Secretary of State staff

The attorney general's form approval did not prevent the secretary of state from rejecting the petition. The opinion identified the secretary of state as the final decision-maker.

Election lawyers and ballot-measure researchers

Opinion 43-2024 distinguishes approval as to form from substantive sufficiency. Its holding also differs from the rejection label on the official archive index.

Common questions

Q: Did the attorney general approve petition 2026-014?
A: Yes, as to form. The opinion did not determine whether the petition was sufficient as to substance.

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 the petition.

Q: Did the approval endorse the petition's objectives?
A: No. The opinion expressly disclaimed endorsement and did not express a view about the petition's general adequacy.

Background and statutory framework

The Missouri Secretary of State requested review on December 19, 2024. The attorney general reviewed Jamie Howard's proposed Article III constitutional amendment, petition 2026-014, under § 116.332, RSMo.

The opinion approved the petition as to form while reserving final authority to the secretary of state. It also separated form review from any decision on substance or the proposal's merits.

Citations and references

Statute: § 116.332, RSMo.

Source

• Landing page: https://ago.mo.gov/other-resources/ag-opinions/2020-opinions/2024-opinions/
• Original PDF: https://ago.mo.gov/wp-content/uploads/43-2024.pdf

Original opinion text

ATTORNEY GENERAL OF MISSOURI
ANDREW BAILEY
December 30, 2024
OPINION LETTER NO. 43-2024

The Honorable John R. Ashcroft
Missouri Secretary of State
James C. Kirkpatrick State Information Center
600 West Main Street
Jefferson City, MO 65101
Dear Secretary Ashcroft:

This opinion letter responds to your request dated December 19, 2024 for our
review under § 116.332, RSMo of the sufficiency as to form of an initiative petition
to amend Article III, of the Missouri Constitution submitted by Jamie Howard,
2026-014.
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

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

OP-2024-045