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The Governor has discretion to determine when an “extraordinary occasion” warrants a special legislative session

In a unanimous opinion, the Court affirmed a declaratory judgment for the State in a challenge to the Governor’s authority to call an extraordinary session of the General Assembly. The text of article IV, section 9, which centers on what the Governor “deems necessary,” gives the Governor discretion to determine both when an extraordinary occasion exists and what matters the General Assembly may consider. The Court declined to read into the Constitution any requirement that the occasion satisfy an external definition of “extraordinary.” Applying that reading to Governor Kehoe’s August 2025 proclamation convening the Second Extraordinary Session to address congressional redistricting and the initiative petition process, the Court held the Governor acted within his constitutional authority and did not reach the circuit court’s alternative political question ruling.

SC101541 NAACP Missouri State Conference v. Kehoe