Why did Missouri reject Zachary Dowdle's initiative petition 2026-073?
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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 Zachary Dowdle's initiative petition 2026-073 as to form. The petition did not correctly identify the number of sections proposed for revision, as required by Section 116.050.
The opinion arose from a form-sufficiency review under § 116.332, RSMo. It did not endorse the petition or express a view about the proposal's objectives or general adequacy.
What this means for you
Initiative petition proponents
Petition 2026-073 failed the attorney general's form review because its stated number of sections proposed for revision was incorrect.
Missouri election officials
Opinion 132-2025 records the Section 116.050 defect identified during review under § 116.332, RSMo.
Election lawyers and ballot-measure researchers
The opinion addressed the petition's form and did not make a substantive-sufficiency determination.
Common questions
Q: Why was petition 2026-073 rejected?
A: It did not correctly identify the number of sections proposed for revision.
Q: Which requirement did the opinion cite?
A: Section 116.050.
Q: Did the opinion decide whether the proposal was substantively sufficient?
A: No. The opinion described a form-sufficiency review and did not make a substantive determination.
Background and statutory framework
The Missouri Secretary of State requested review on July 16, 2025. The petition proposed an amendment to Article III of the Missouri Constitution and was identified as 2026-073.
The attorney general reviewed the petition under § 116.332, RSMo and rejected it on July 25, 2025 for the Section 116.050 defect.
Citations and references
Statutes: § 116.332, RSMo; Section 116.050.
Source
- Landing page: https://ago.mo.gov/other-resources/ag-opinions/
- Original PDF: https://ago.mo.gov/wp-content/uploads/132-2025.pdf
Original opinion text
ATTORNEY GENERAL OF MISSOURI
ANDREW BAILEY
July 25, 2025
OPINION LETTER NO. 132-2025
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 16, 2025 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 Zachary Dowdle, 2026-073.
We conclude that the petition must be rejected for at least the following reasons:
Failure to correctly identify the number of sections proposed for revision as required by Section 116.050.
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
OP-2025-144
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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