MO Opinion No. 329-2025 November 10, 2025

What referendum summary did Missouri approve for House Bill 1 and new congressional boundaries?

Short answer: The Attorney General approved the legal content and form of the submitted summary for referendum petition 2026-R004. The approved wording asked voters whether to approve House Bill 1, describing it as replacing an existing gerrymandered plan that protected incumbents with more intact, compact boundaries that better reflected statewide voting patterns.

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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 AG opinions are persuasive authority but not binding precedent.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 Catherine L. Hanaway approved the legal content and form of the proposed referendum summary for Richard von Glahn's petition 2026-R004 concerning House Bill 1.

The approved wording asked whether voters approved House Bill No. 1 from the 2025 Second Extraordinary Session. The submitted summary described the act as repealing Missouri's existing "gerrymandered congressional plan that protects incumbent politicians" and replacing it with boundaries that kept more cities and counties intact, were more compact, and better reflected statewide voting patterns.

Those characterizations were part of the approved ballot wording. The Attorney General's review under § 116.334, RSMo was limited to legal content and form and did not endorse the petition or its objectives.

What this means for you

Voters and redistricting researchers

Opinion 329-2025 preserves the exact framing approved for the referendum summary, including its descriptions of the prior and replacement congressional plans.

Referendum proponents

The proposed summary passed legal-content and form review. The opinion did not endorse the referendum.

Missouri election officials

The approved wording identified House Bill No. 1 and the 2025 Second Extraordinary Session and framed the question as voter approval of that act.

Common questions

Q: What act did the referendum concern?
A: House Bill No. 1 from Missouri's 2025 Second Extraordinary Session.

Q: How did the approved wording describe the new boundaries?
A: As keeping more cities and counties intact, being more compact, and better reflecting statewide voting patterns.

Q: Did the Attorney General independently find that the prior plan was gerrymandered?
A: The opinion approved the legal content and form of a proposed statement containing that characterization. It expressly disclaimed endorsement of the petition or its objectives.

Background and statutory framework

The Secretary of State requested review on October 31, 2025. The proposed summary concerned Richard von Glahn's referendum petition 2026-R004 on House Bill 1.

The Attorney General issued Opinion 329-2025 on November 10, 2025 and approved the summary's legal content and form under § 116.334, RSMo.

Citations and references

Statute: § 116.334, RSMo.

Source

Original opinion text

ATTORNEY GENERAL OF MISSOURI
CATHERINE L. HANAWAY

November 10, 2025

OPINION LETTER NO. 329-2025

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 October 31, 2025, for our review under § 116.334, RSMo, of a proposed summary statement prepared for the petition submitted by Richard von Glahn (2026-R004) regarding a referendum for House Bill 1. The proposed summary statement is as follows:

Do the people of the state of Missouri approve the act of the General Assembly entitled "House Bill No. 1 (2025 Second Extraordinary Session)," which repeals Missouri's existing gerrymandered congressional plan that protects incumbent politicians, and replaces it with new congressional boundaries that keep more cities and counties intact, are more compact, and better reflects statewide voting patterns?

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,

CATHERINE L. HANAWAY
Attorney General

OP-2025-350

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