Did Missouri approve the form of Terrence Wise's initiative petition to amend Article VI?

Plain-English summary

Missouri Attorney General Andrew Bailey approved, as to form, an initiative petition submitted by Terrence Wise to amend Article VI, version 1, of the Revised Statutes of Missouri, identified as petition 2026-039. The review under § 116.332, RSMo checks only the form of a petition. The opinion stressed that the Secretary of State keeps the final authority to approve or reject the petition, so the attorney general's approval does not preclude a rejection.

The opinion also warned that approving the form is not a finding that the petition is sufficient as to substance, and that the review is not an endorsement of the petition or its objectives.

What this means for you

Initiative proponents

A form approval clears a procedural hurdle, but it is not the final word. Under § 116.332, the Secretary of State can still reject the petition, and the attorney general took no position on whether the petition's content holds up.

Missouri voters and researchers

Opinion 57-2025 records that Terrence Wise's petition 2026-039 passed the attorney general's form review. It says nothing about whether the underlying proposal is sound or will reach the ballot.

Common questions

Q: What does "approved as to form" mean here?
A: The attorney general checked the petition's form under § 116.332, RSMo. It is not a ruling on the substance of the proposal.

Q: Who has the final say on the petition?
A: The Secretary of State. The opinion says its approval of form does not preclude the Secretary from rejecting the petition.

Q: Did the attorney general endorse the petition?
A: No. The review is mandated by statute and is not an endorsement of the petition or its objectives.

Background and statutory framework

The Secretary of State requested review by letter dated May 13, 2025. Under § 116.332, RSMo, the attorney general reviews an initiative petition as to form, while the Secretary of State holds final authority to approve or reject it. The attorney general approved the form on May 23, 2025.

The proposal was identified as Terrence Wise's petition 2026-039, amending Article VI, version 1.

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/57-2025.pdf

Original opinion text

ATTORNEY GENERAL OF MISSOURI
ANDREW BAILEY

May 23, 2025

OPINION LETTER NO. 57-2025

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 May 13, 2025 for our review under § 116.332, RSMo of the sufficiency as to form of an initiative petition to amend Article VI, version 1, Revised Statutes of Missouri, submitted by Terrence Wise, 2026-039.

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,

ANDREW BAILEY
Attorney General

OP-2025-063

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