MO Opinion No. 122-2025 July 11, 2025

Did Missouri approve ballot wording protecting citizen laws and rejected referendums from legislative changes?

Short answer: Yes. The approved statement described an 80% referral threshold for changing citizen-initiated laws or enacting laws similar to rejected referendum measures, covering past and future measures and preserving vote and signature requirements.

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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 AG opinions are persuasive authority but not binding precedent.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 Andrew Bailey approved the legal content and form of the proposed summary statement for Jamie Howard's initiative petition 2026-061. The statement described prohibiting legislative changes to laws passed by citizen initiative or enactment of laws similar to those rejected by referendum unless 80% of legislators referred the change to voters. It said the protection would cover past and future measures.

It also described barring legislatively proposed constitutional amendments from restricting initiative or referendum powers, general-election placement for most measures unless 80% of legislators and the governor approved a special election, immediate judicial correction of misleading ballot titles, and preservation of existing vote and signature requirements. The opinion did not endorse the petition.

What this means for you

Missouri voters and initiative proponents

The reviewed statement described protections for past and future citizen-initiated laws, referendum results, and existing majority-vote and signature requirements.

State legislators and election officials

The statement described an 80% legislative referral threshold and general-election placement for most measures unless the stated special-election threshold was met.

Courts, citizens, and election lawyers

The statement described mandating immediate judicial correction of misleading ballot titles.

Common questions

Q: What laws did the statement protect?
A: Laws passed by citizen initiative and laws similar to those rejected by referendum, including past and future measures.

Q: What threshold did it identify for legislative changes?
A: Eighty percent of legislators to refer the change to voters.

Q: What did it say about ballot titles?
A: It described immediate judicial correction of misleading titles.

Q: What petition rules would remain?
A: Existing majority-vote and signature requirements for citizen-initiated laws and amendments.

Background and statutory framework

The Missouri Secretary of State requested review on July 2, 2025. The attorney general reviewed the proposed summary statement under § 116.334, RSMo and approved it on July 11, 2025.

The proposal was identified as Jamie Howard's petition 2026-061. The opinion reproduced the statement's five provisions concerning citizen measures, legislative thresholds, elections, ballot titles, and petition requirements.

Citations and references

Statute: § 116.334, RSMo.

Source

Original opinion text

ATTORNEY GENERAL OF MISSOURI
ANDREW BAILEY

July 11, 2025

OPINION LETTER NO. 122-2025

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 2, 2025 for our review under § 116.334, RSMo of a proposed summary statement prepared for the petition submitted by Jamie Howard, 2026-061. The proposed summary statement is as follows:

Shall the Missouri Constitution be amended to:

• Prohibit the legislature from changing laws passed by citizen initiative or enacting laws similar to those rejected by referendum, unless 80% of legislators refer the change to voters, including both past and future measures;

• Bar legislatively proposed constitutional amendments from restricting initiative or referendum powers;

• Require most ballot measures to appear at general elections unless a special election is approved by 80% of legislators and the governor;

• Mandate immediate judicial correction of misleading ballot titles; and

• Preserve existing majority vote and signature requirements for citizen-initiated laws and amendments?

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,

ANDREW BAILEY
Attorney General

OP-2025-134

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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