What fiscal impact did Missouri approve for Spencer Toder's initiative petition 2026-070?

Plain-English summary

Missouri Attorney General Andrew Bailey approved the legal content and form of the fiscal note summary for Spencer Toder's initiative petition 2026-070. The summary reported that Southeast Missouri State University estimated an unknown fiscal impact. It also reported at least $427,516 in annual increased operating costs for the Attorney General's Office and unknown Legal Expense Fund costs that could exceed $1 million. Other state and local governmental entities estimated no costs or savings.

The review was limited. Under § 116.175.4, RSMo, the attorney general did not examine the fairness or sufficiency of the estimated fiscal impact and did not endorse the petition or its objectives.

What this means for you

Initiative petition proponents

The fiscal note summary for petition 2026-070 passed the attorney general's legal-content and form review. The opinion did not evaluate whether the estimates were fair or sufficient.

Missouri State Auditor staff

The approved summary preserved the reported uncertainty for Southeast Missouri State University and the Legal Expense Fund while stating a minimum annual operating-cost estimate for the Attorney General's Office.

State and local government researchers

Opinion 169-2025 records the reviewed fiscal estimates: an unknown university impact, at least $427,516 in annual attorney general operating costs, potential Legal Expense Fund costs above $1 million, and no estimated costs or savings for other state and local entities.

Common questions

Q: What costs did the fiscal note summary report?
A: It reported an unknown impact on Southeast Missouri State University, at least $427,516 in annual increased Attorney General's Office operating costs, and unknown Legal Expense Fund costs that could exceed $1 million.

Q: Did other government entities estimate costs or savings?
A: No. The summary said other state governmental entities and local governmental entities estimated no costs or savings.

Q: Did the attorney general verify that the estimates were fair or sufficient?
A: No. The opinion expressly said the review under § 116.175.4 did not examine the fairness or sufficiency of the estimated fiscal impact.

Background and statutory framework

The Missouri State Auditor submitted the fiscal note and fiscal note summary on July 23, 2025. They were prepared under § 116.175, RSMo for Spencer Toder's petition 2026-070.

The attorney general issued the approval on August 1, 2025. The opinion limited its review to legal content and form and disclaimed any endorsement of the petition.

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/169-2025.pdf

Original opinion text

ATTORNEY GENERAL OF MISSOURI
ANDREW BAILEY

August 1, 2025

OPINION LETTER NO. 169-2025

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 July 23, 2025, submitting a fiscal note and fiscal note summary prepared under § 116.175, RSMo, for an initiative petition submitted by Spencer Toder, 2026-070. The fiscal note summary that you submitted is as follows:

Southeast Missouri State University estimates an unknown fiscal impact. The Attorney General's Office estimates annual increased operating costs of at least $427,516 and unknown costs to the Legal Expense Fund that could exceed $1 million. Other state governmental entities estimate no costs or savings. 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,

ANDREW BAILEY
Attorney General

OP-2025-181

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