Why did Missouri reject Jamie Howard's initiative petition 2026-051?
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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.
Plain-English summary
Missouri Attorney General Andrew Bailey rejected Jamie Howard's initiative petition 2026-051 as to form. The petition's signature sheet failed to address the current secretary of state correctly, as required by Section 116.040.
The attorney general did not review the petition for additional deficiencies after identifying that defect. Under § 116.332.4, RSMo, the secretary of state retained authority to make the final decision on approval or rejection of the petition's form.
What this means for you
Initiative petition proponents
Petition 2026-051 failed the attorney general's form review because of the addressee on its signature sheet. The opinion did not determine whether other deficiencies existed.
Missouri election officials
The opinion identified the signature-sheet defect and stated that § 116.332.4, RSMo authorized the secretary of state to make the final form decision.
Election lawyers and ballot-measure researchers
Opinion 69-2025 records a form rejection based on Section 116.040 and leaves any additional defects unexamined.
Common questions
Q: Why was petition 2026-051 rejected?
A: Its signature sheet did not correctly address the current secretary of state.
Q: Did the attorney general identify every possible defect?
A: No. The opinion said the petition was not reviewed for additional deficiencies after the stated defect required rejection.
Q: Who made the final decision on the petition's form?
A: The opinion said § 116.332.4, RSMo authorized the secretary of state to make the final approval or rejection decision.
Background and statutory framework
The Missouri Secretary of State requested review on May 19, 2025. The petition was Jamie Howard's Article III version 4 proposal, identified as 2026-051.
The attorney general reviewed the petition under § 116.332, RSMo and rejected it on May 29, 2025. The stated defect was failure to address the signature sheet correctly under Section 116.040.
Citations and references
Statutes: § 116.332, RSMo; Section 116.040; § 116.332.4, RSMo.
Source
- Landing page: https://ago.mo.gov/other-resources/ag-opinions/
- Original PDF: https://ago.mo.gov/wp-content/uploads/69-2025.pdf
Original opinion text
ATTORNEY GENERAL OF MISSOURI
ANDREW BAILEY
May 29, 2025
OPINION LETTER NO. 69-2025
The Honorable Denny Hoskins
Missouri Secretary of State
James C. Kirkpatrick State Information Center
600 West Main Street
Jefferson City, MO 65101
Dear Secretary Ashcroft:
This opinion letter responds to your request dated May 19, 2025 for our review under § 116.332, RSMo of the sufficiency as to form of an initiative petition submitted by Jamie Howard, Article III, version 4, 2026-051
We conclude that the petition must be rejected for at least the following reason:
failure to correctly address the signature sheet to the current secretary of state as required in Section 116.040.
Because of our rejection of the form of the petition for the reasons stated above, we have not reviewed the petition to determine whether additional deficiencies exist. Pursuant to § 116.332.4, RSMo, the Secretary of State is authorized to review this opinion and “make a final decision as to the approval or rejection of the form of the petition.”
Very truly yours,
ANDREW BAILEY
Attorney General
OP-2025-075
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
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