Did Missouri approve the form of Richard von Glahn's version 4 referendum petition on House Bill 1?

Plain-English summary

Missouri Attorney General Catherine L. Hanaway approved Richard von Glahn's version 4 referendum petition 2026-R004 on House Bill No. 1 as sufficient as to form.

The approval was limited. Under § 116.332, RSMo, the Secretary of State retained final authority to approve or reject the petition. The opinion also said that form approval did not determine substantive sufficiency or endorse the petition's objectives.

What this means for you

Referendum proponents

Version 4 of the House Bill No. 1 referendum petition passed the Attorney General's form review. The opinion did not decide whether it was substantively sufficient.

Missouri election officials

The Attorney General's approval did not remove the Secretary of State's final authority to approve or reject the petition.

Election lawyers and ballot-measure researchers

Opinion 314-2025 records a form-sufficiency approval for referendum petition 2026-R004 and expressly limits the effect of that approval.

Common questions

Q: Was referendum petition 2026-R004 approved as to form?
A: Yes. The Attorney General approved version 4 as sufficient as to form.

Q: Could the Secretary of State still reject it?
A: Yes. The opinion said § 116.332 gave the Secretary of State final authority to approve or reject the petition.

Q: Did the opinion decide whether the petition was substantively sufficient?
A: No. The Attorney General expressly limited the review to form.

Background and statutory framework

The Missouri Secretary of State requested review on September 29, 2025. The request concerned Richard von Glahn's version 4 referendum petition on House Bill No. 1 from the 103rd General Assembly's Second Extraordinary Session.

The Attorney General issued Opinion 314-2025 on October 9, 2025 and approved the petition as to form under § 116.332, RSMo.

Citations and references

Statute: § 116.332, RSMo.

Source

• Landing page: https://ago.mo.gov/other-resources/ag-opinions/
• Original PDF: https://ago.mo.gov/wp-content/uploads/314-2025.pdf

Original opinion text

ATTORNEY GENERAL OF MISSOURI
CATHERINE L. HANAWAY

October 9, 2025

OPINION LETTER NO. 314-2025

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 September 29, 2025, for our review under § 116.332, RSMo, of the sufficiency as to form of a referendum petition for House Bill No. 1 (103rd General Assembly, 2nd Extraordinary Session) submitted by Richard von Glahn, version 4 (2026-R004).

We approve the petition as to form, but § 116.332 gives the Secretary of State final authority to approve or reject the petition. Therefore, our approval of the form of the petition does not preclude you from rejecting the petition.

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-2025-333

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