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Insufficiency certificate stating no reason “preserves nothing for this Court’s review”

In a unanimous opinion, the Court reversed the circuit court’s judgment upholding the secretary of state’s certificate of insufficiency in an initiative petition case. The Court held that a certificate declaring a petition insufficient without identifying any reason fails to comply with the secretary’s statutory duty to state the reason and preserves nothing for judicial review, and that the secretary’s review is ministerial and does not extend to whether the amendment, if approved, might later violate the constitution. Even treating the secretary’s arguments as preserved, the Court found the post-adoption claims unripe and the single-subject and single-article claims meritless, held the secretary lacked authority to vacate the ballot title he had certified in September 2025 and issue a new one, and entered judgment ordering the petition onto the November 2026 ballot with the original ballot title.

SC101806 Claire Harris, et al. v. Denny Hoskins, in His Official Capacity as the Missouri Secretary of State