Why did the Missouri attorney general reject Jasmine Miller's 2026 initiative petition?

Plain-English summary

Missouri Attorney General Catherine L. Hanaway rejected Jasmine Miller's initiative petition to amend Article I of the Missouri Constitution. The stated reason was the petition's failure to comply with the form requirements in Section 116.050.

The attorney general's review was limited to sufficiency as to form under § 116.332, RSMo. The opinion did not decide whether the petition was sufficient as a matter of substance and did not endorse the petition or its objectives.

What this means for you

Initiative petition proponents

The opinion treated compliance with Section 116.050's form requirements as necessary for the petition to pass the attorney general's form review. It did not identify or decide any substantive defect in Miller's proposal.

Missouri election officials

The attorney general concluded that petition 2026-148 had to be rejected at the form-review stage. The opinion did not reach the proposal's merits.

Election lawyers and ballot-measure researchers

Opinion 2-2026 states one ground for rejection: failure to comply with Section 116.050. It also preserves the distinction between form review under § 116.332, RSMo, and substantive sufficiency.

Common questions

Q: Why was Jasmine Miller's petition rejected?
A: It failed to comply with the form requirements in Section 116.050.

Q: Did the attorney general decide that the proposal was substantively invalid?
A: No. The opinion said the form review should not be construed as a determination about sufficiency as to substance.

Q: What constitutional provision would the petition have amended?
A: Article I of the Missouri Constitution.

Background and statutory framework

The Missouri Secretary of State requested review on February 3, 2026. The petition, identified as 2026-148, proposed an amendment to Article I of the Missouri Constitution.

The attorney general conducted a sufficiency-as-to-form review under § 116.332, RSMo. On February 13, 2026, the attorney general concluded that the petition had to be rejected because it did not comply with Section 116.050's form requirements.

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/002_2026.pdf

Original opinion text

ATTORNEY GENERAL OF MISSOURI
CATHERINE L. HANAWAY

February 13, 2026

OPINION LETTER NO. 2-2026

The Honorable Denny Hoskins, CPA
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 February 3, 2026, for our review under § 116.332, RSMo, of the sufficiency as to form of an initiative petition to amend Article I, of the Missouri Constitution submitted by Jasmine Miller (2026-148).

We conclude that the petition must be rejected for at least the following reason:

Failure to comply with the form requirements contained in 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,

CATHERINE L. HANAWAY
Attorney General

OP-2026-002

Supreme Court Building, 207 W. High Street, P.O. Box 899, Jefferson City, MO 65102 | Phone: (573) 751-3321 | www.ago.mo.gov