On Friday January 23, 2026, The Missouri Supreme Court unanimously declared Senate Bill 22 (SB 22) unconstitutional in its entirety, finding it violated the “original purpose” requirement of the Missouri Constitution.

SB 22 was first introduced as a bill that changed the process by which a court can review ballot summary statements and allowed the secretary of state or the General Assembly to revise the statement if a court finds it insufficient or unfair. (KOMU)

The bill had amendments added last year that were not related to the original SB 22 title, including one that added a provision allowing the Missouri attorney general to appeal temporary blocks a court makes on state laws.

Chief Justice W. Brent Powell wrote the judgement saying the changes violated the Missouri Constitution’s requirement that amendments should not change the original purpose of legislation. 

On January 7, the state argued the changes and amendments are germane to the original purpose. 

Powell noted that the power granted to the attorney general “goes beyond SB 22’s initial purpose related to ballot summaries.  The state’s argument stretches the boundaries of logic.”  Judge Powell wrote.

“The decision restates what lawmakers should have known when they passed the bill because what is and is not allowed procedurally has been argued repeatedly in court” attorney Chuck Hatfield said.

Hatfield represented Sean Nicholson, who sued in part because the new ballot summary process is more expensive and creates delays for ballot initiatives.

“Every few years, the Supreme Court needs to remind the Legislature that they have to follow the procedural requirements of the Constitution when they pass a bill,” Hatfield said. “It’s not that hard. They need to vote on things separately.” (Missouri Independent)

It’s important to note that SB 22 was thrown out because of the way it was passed, not because of the content of the bill.  It’s also relevant to note that the management of the Missouri Senate and the bill handlers were warned that they were violating the constitution and they proceeded anyway.   

There are several lawsuits in Missouri challenging bills passed by our state legislature where they did not follow the simple constitutional rules of:  One subject per bill. The content of the bill must be germane to the title.  The purpose of the bill cannot be changed.

State law makers often lump various bills together in omnibus bills, sometimes called ‘Christmas Tree’ bills in order to pass their legislation.  The conversation might go like this:  “I will vote for your bill if you add my bill as an amendment and then we both get what we want passed”   This is how bad bills that could not pass on their own can become law.   

Learn more at article3institute.org/