Justia Missouri Supreme Court Opinion Summaries

Several individuals and two organizations challenged a Missouri law enacted in 2022, House Bill No. 1878 (HB 1878), which amended the state’s voting requirements by mandating that voters present specific forms of photo identification or cast a provisional ballot under certain conditions. The organizations—the Missouri State Conference of the NAACP and the League of Women Voters of Missouri—along with the individuals, claimed that these provisions unconstitutionally burdened the right to vote and violated equal protection guarantees.Their petition for declaratory and injunctive relief was filed in the Circuit Court of Cole County. After a bench trial, the circuit court found that none of the individual plaintiffs had shown an actual or threatened injury, as each had either successfully voted since the law’s enactment or their alleged difficulties were speculative. The court also determined that the organizations had not established standing, either through a diversion of resources or by identifying any specific member adversely affected by the law. Despite these findings, the circuit court proceeded to rule on the merits, concluding the law was constitutional.The Supreme Court of Missouri, which has exclusive jurisdiction in cases involving the validity of state statutes, reviewed the matter. The Supreme Court affirmed the circuit court’s determination that the appellants lacked standing—meaning none of the plaintiffs demonstrated a concrete, personal stake in the outcome. The Supreme Court held that, because there was no justiciable controversy before the court, the circuit court erred by reaching and deciding the merits of the constitutional claims. Therefore, the Supreme Court reversed that portion of the judgment addressing the merits of the constitutional challenge. The case was thus resolved solely on the issue of standing. View "Missouri State Conference of the National Association for the Advancement of Colored People vs. State" on Justia Law

In 2022, Missouri enacted new legislation that imposed several restrictions on activities related to voter registration and absentee ballot applications. The law prohibited the payment or compensation of individuals for soliciting voter registration applications unless they were government employees, required anyone who solicited more than ten voter registration applications to register with the state, and mandated that solicitors be at least eighteen years old and registered Missouri voters. Additionally, the law completely banned the solicitation of voters to obtain absentee ballot applications. These provisions affected organizations whose work involves encouraging and assisting individuals in registering to vote and informing them about absentee voting.The Circuit Court of Cole County reviewed a lawsuit brought by two civic organizations challenging these provisions as unconstitutional. The organizations argued the restrictions violated rights to free speech, association, and due process under the Missouri Constitution. The court issued a preliminary injunction, and after trial, permanently enjoined enforcement of the provisions, finding them to be facially unconstitutional restrictions on core political speech, overbroad, content- and viewpoint-based, and unconstitutionally vague. The court concluded the state had not shown the provisions were narrowly tailored to serve a compelling governmental interest.On direct appeal, the Supreme Court of Missouri affirmed the circuit court’s judgment. The Supreme Court of Missouri held that the statutory provisions imposed facially unconstitutional restrictions on core political speech protected by article I, section 8 of the Missouri Constitution. The Court found the provisions neither served a compelling state interest nor were narrowly tailored, and instead captured substantial amounts of protected speech unrelated to any compelling interest. The judgment declaring the provisions unconstitutional was affirmed. View "State vs. League of Women Voters" on Justia Law

After the results of the 2020 United States census were certified to the governor of Missouri in August 2021, the Missouri General Assembly established new congressional districts in 2022, as required by the state constitution. In September 2025, the General Assembly passed House Bill 1 (“HB 1”), which repealed the 2022 congressional districts and established new ones, even though no new census had been certified. The governor signed HB 1 into law. A group of plaintiffs challenged the constitutionality of HB 1, arguing that article III, section 45 of the Missouri Constitution restricts the General Assembly to one redistricting following each decennial census certification.The Circuit Court of Cole County heard the case on stipulated facts and rejected the plaintiffs’ claim, finding that HB 1 was a valid exercise of the General Assembly’s legislative authority. The circuit court declared that article III, section 45 does not prevent the General Assembly from redistricting more frequently than once per decade.On appeal, the Supreme Court of Missouri reviewed the constitutional question de novo. The Court held that article III, section 45 obligates the General Assembly to redistrict upon certification of the decennial census but does not expressly prohibit mid-decade or more frequent congressional redistricting. The Court explained that, absent express constitutional restraint, the General Assembly’s legislative power remains plenary. The Court also found that the word “when” in section 45 acts as a trigger for mandatory redistricting but does not serve as a limitation on the legislature’s authority to redistrict at other times.The Supreme Court of Missouri affirmed the circuit court’s judgment, upholding HB 1 as constitutional and concluding that article III, section 45 does not restrict the General Assembly’s power to conduct mid-decade congressional redistricting. View "Luther vs. Hoskins" on Justia Law

Registered Missouri voters Raymond McCarty, Daniel Shaul, Russell Lahl, and Michael Hastings, along with several nonprofit organizations, contested the results of the November 2024 election approving Proposition A. They argued that the summary statement and fiscal note summary for Proposition A were misleading, casting doubt on the election's fairness and validity. Proposition A proposed increasing the minimum wage, adjusting it based on the Consumer Price Index, requiring paid sick leave, and exempting certain entities.The Missouri Supreme Court reviewed the case. The lower courts had not previously reviewed this specific election contest. The plaintiffs brought the case directly to the Missouri Supreme Court, which has original jurisdiction over election contests under chapter 115 of the Missouri statutes.The Missouri Supreme Court held that the summary statement and fiscal note summary for Proposition A were not misleading or materially inaccurate. The court found that the summary statement fairly and impartially summarized the central features of Proposition A, and the fiscal note summary adhered to statutory requirements by focusing on governmental costs. The court concluded that there was no election irregularity of sufficient magnitude to cast doubt on the election's validity. Additionally, the court dismissed the plaintiffs' claims that Proposition A violated the "single subject" and "clear title" requirements of the Missouri Constitution, citing a lack of original jurisdiction over these claims. The court upheld the election results, affirming the validity of Proposition A. View "McCarty v. Secretary of State" on Justia Law

The case involves a dispute over the form and procedural requirements of an initiative petition for Amendment 3, which aims to protect reproductive freedom. The Attorney General and the Secretary of State had approved the form of the petition in March 2023. Proponents of the amendment collected the necessary signatures, and the Secretary of State certified the petition for the 2024 general election ballot. Opponents challenged the certification, claiming the petition failed to include all constitutional provisions and statutes that might be affected if the amendment were approved.The Circuit Court of Cole County ruled in favor of the opponents, finding that the petition did not meet the requirements of article III, section 50 of the Missouri Constitution and section 116.050.2(2). The court ordered the amendment removed from the ballot. Proponents appealed, and the case was transferred to the Supreme Court of Missouri.The Supreme Court of Missouri reversed the circuit court's decision. The court held that article III, section 50 requires a petition proposing a constitutional amendment to identify only those existing sections of the constitution that are in direct conflict with the proposed amendment. The court found that Amendment 3 did not purport to repeal any existing constitutional provision and was not in direct conflict with any existing constitutional article or section. The court also rejected the opponents' claim that Amendment 3 violated the "single subject" requirement, finding that all provisions of the amendment related to the single subject of protecting reproductive freedom.The court concluded that the Secretary of State's certification of Amendment 3 was correct and ordered the amendment to be placed on the 2024 general election ballot. View "Coleman v. Ashcroft" on Justia Law

In this case, Quinton Lucas, a registered voter, challenged the approval of Amendment No. 4 in the November 2022 general election. The amendment authorized laws that increased minimum funding for a police force established by a state board of police commissioners. Lucas claimed that the fiscal note summary printed on every ballot cast in the election materially misstated the fiscal note for the measure.The Supreme Court of Missouri, which was reviewing the case, had previously overruled the state's motion to dismiss Lucas' claim. The state had argued that Lucas' contest was time-barred, that the city lacked standing as a voter, and that the statutes providing remedies if an election contest succeeds were unconstitutional.The Supreme Court of Missouri found that the fiscal note summary was both materially inaccurate and seriously misleading. The court held that this constituted an "irregularity" of sufficient magnitude to cast doubt on the validity of the election. As a result, the court ordered a new election on the question to be conducted as part of the statewide general election on November 5, 2024. View "Lucas vs. Ashcroft" on Justia Law

In this case, the Supreme Court of Missouri affirmed a lower court's decision that a redistricting plan for the Missouri Senate, which was prepared by a judicial redistricting commission, met constitutional requirements. The appellants, residents of districts impacted by the redistricting, argued that the plan violated the community preservation requirement of the Missouri Constitution by splitting certain communities into different senatorial districts. The court found the appellants did not meet their burden of proving the plan was clearly and undoubtedly unconstitutional. The court noted that the constitution allows for some flexibility in the redistricting process and that the plan need not achieve absolute perfection. The court concluded that the redistricting plan did not violate the constitutional requirements and was not the result of partisan or racial gerrymandering. View "Faatz v. Ashcroft" on Justia Law

The Supreme Court vacated the order of the circuit court entering a declaratory judgment that Mo. Rev. Stat. 115.646 violated public officials' right to free speech and was void for vagueness, holding that the circuit court erred.Section 115.646 prohibits officials from directly using public funds to advocate, support, or oppose a ballot measure or candidate for public office. Plaintiffs initiated a lawsuit seeking a judgment declaring section 115.646 unconstitutional. The circuit court sustained Plaintiffs' motion for summary judgment, declaring that section 115.646 violated the officials' First Amendment rights. The Supreme Court vacated the judgment, holding (1) because section 115.646 regulates the use of public funds, not the officials' speech, it does not implicate the free speech clause of the First Amendment; and (2) the circuit court erred in declaring certain words and phrases in the statute to be unconstitutionally vague. View "City of Maryland Heights v. State" on Justia Law

The Supreme Court affirmed the order of the circuit court issuing a declaratory judgment invalidating Mo. Rev. Stat. 116.180 and 116.334.2, which prohibit the collection of referendum petition signatures before the Secretary of State has certified the referendum's official ballot title and affixed it to the petition, holding that there was no error.In invalidating sections 116.180 and 116.334.2, the circuit court declared that those provisions interfere with and impede the right of referendum, therefore conflicting with Mo. Const. art. III, 49 and 52(a). The Supreme Court affirmed the judgment declaring those statutes constitutionally invalid, holding that the statutes' prohibition on collecting referendum petition signatures before the Secretary certifies the official ballot title unreasonably shores the timeframe for petition circulation, thus interfering with and impeding the constitutional right of referendum reserved to the people. View "No Bans on Choice v. Ashcroft" on Justia Law

The Supreme Court affirmed the judgment of the circuit court denying Appellants' request for injunctive and declaratory relief that allows all Missouri voters to vote by mail without having their signatures on their ballot envelopes acknowledged by a notary or other official authorized by law to administer oaths, holding that the request for relief was not supported or warranted by Missouri law.In the face of the ongoing public health crisis caused by the COVID-19 pandemic, the Missouri legislature expanded voting options for 2020 elections but put in place certain limitations on the newly created mail-in voting system. Appellants challenged one of those limitations - that absentee and mail-in ballot envelopes be notarized for certain voters. The circuit court denied relief. The Supreme Court affirmed, holding (1) the circuit court did not err in ruling that the plain and ordinary meaning of Mo. Rev. Stat. 115.277.1(2) does not allow Missouri voters who expect to confine themselves to avoid contracting the COVID-19 virus to vote absentee without notarization; and (2) where there is no constitutional right in Missouri to vote by absentee or mail-in ballot, Appellants' constitutional claims were without merit. View "Missouri State Conference of National Ass'n for Advancement of Colored People v. State" on Justia Law