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Stay application appendix, volume 1
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No. 26A____
In the
Supreme Court of the United States
DENNY HOSKINS, in his official capacity as Missouri Secretary of State,
Applicant,
v.
RICHARD VON GLAHN,
Respondent.
APPENDIX TO EMERGENCY APPLICATION FOR STAY AND
ADMINISTRAIVE STAY PENDING APPEAL
VOL. I OF V
APPENDIX
Volume I
Opinion of the Missouri Supreme Court
(September 3, 2026) ................................................................................................. 1a
Mandate of the Missouri Supreme Court
(September 3, 2026) ............................................................................................... 15a
Order Denying Stay by the Missouri Supreme Court
(September 4, 2026) ............................................................................................... 16a
Judgment of the Circuit Court of Cole County, Missouri
(August 19, 2026) ................................................................................................... 17a
Petition for Declaratory Judgment and Injunctive Relief Under Section 116.200
(August 4, 2026) ..................................................................................................... 54a
Exhibit 1 to Petition for Declaratory Judgment and Injunctive Relief Under Section
116.200
(August 4, 2026) ..................................................................................................... 63a
Exhibit 2 to Petition for Declaratory Judgment and Injunctive Relief Under Section
116.200
(August 4, 2026) ..................................................................................................... 88a
Exhibit 3 to Petition for Declaratory Judgment and Injunctive Relief Under Section
116.200
(August 4, 2026) ..................................................................................................... 91a
Exhibit 4 to Petition for Declaratory Judgment and Injunctive Relief Under Section
116.200
(August 4, 2026) ................................................................................................... 103a
Exhibit 5 to Petition for Declaratory Judgment and Injunctive Relief Under Section
116.200
(August 4, 2026) ................................................................................................... 232a
Order Granting Amended Motion to Intervene of Republican National Committee,
National Republican Congressional Committee, and Missouri Republican State
Committee
(August 13, 2026) ................................................................................................. 242a
Secretary of State’s Answer to the Petition and Affirmative Defenses
(August 18, 2026) ................................................................................................. 252a
Intervenors Republican Nataional Committee, National Republican Congressional
Committee, and Missouri Republican State Committee’s Answer to Petition for
Declaratory Judgment and Injunction Relief Under Section 116.200
(August 9, 2026) ................................................................................................... 260a
Secretary of State’s Pre-Trial Brief
(August 18, 2026) ................................................................................................. 273a
Intervenors’ Trial Brief
(August 18, 2026) ................................................................................................. 331a
Plaintiff’s Trial Brief
(August 18, 2026) ................................................................................................. 362a
Joint Stipulation of Facts and Exhibits
(August 18, 2026) ................................................................................................. 399a
Volume II
Stipulated Exhibit 1 – Referendum Petition 2026-R004 ....................................... 408a
Stipulated Exhibit 2 – October 14, 2025 Letter Approving Referendum Petition
2026-R004 as to Form .......................................................................................... 474a
Stipulated Exhibit 3 – Signature Pages Submitted to the Local Election Authorities
for Referendum Petition 2026-R004 ................................................................... 477a 1
Stipulated Exhibit 4 – August 6, 2026 Report PM-007 for Referendum Petition
2026-007 ............................................................................................................... 478a
Stipulated Exhibit 5 – August 4, 2026 Certificate of Insufficiency for Referendum
Petition 2026-R004 ............................................................................................... 597a
Stipulated Exhibit 6 – Complaint, Missouri General Assembly v. von Glahn,
No. 4:25-cv-01535-ZMB (E.D. Mo. Oct. 15, 2026) ............................................... 607a
Stipulated Exhibit 7 – Motion for Preliminary Injunction, Missouri General
Assembly v. von Glahn, No. 4:25-cv-01535-ZMB (E.D. Mo. Oct. 15, 2025) ........ 632a
1 Stipulated Exhibit 3 was submitted to the circuit court via a flash drive because of
its voluminous contents. A copy of the flash drive can be provided on request.
Stipulated Exhibit 8 – Memorandum and Order, Missouri General Assembly v. von
Glahn, No. 4:25-cv-01535-ZMB (E.D. Mo. Dec. 8, 2025) .................................... 636a
Stipulated Exhibit 9 – State of Missouri’s Motion to Alter Judgment and
Memorandum in Support, Missouri General Assembly v. von Glahn, No. 4:25-cv01535-ZMB (E.D. Mo. Jan. 5, 2026) .................................................................... 648a
Stipulated Exhibit 10 –Memorandum and Order, Missouri General Assembly v. von
Glahn, No. 4:25-cv-01535-ZMB (E.D. Mo. May 11, 2026) .................................. 665a
Stipulated Exhibit 11 – Make Your Voice Heard: Missouri’s Initiative Petition
Process .................................................................................................................. 673a
Stipulated Exhibit 12 – October 15, 2025 Press Release from the Secretary of State
............................................................................................................................... 717a
Stipulated Exhibit 13 – October 16, 2025 Press Release from the Secretary of State
............................................................................................................................... 719a
Stipulated Exhibit 14 – Jason Rosenbaum, Missouri Republicans learn that
redrawing congressional lines isn’t so easy, St. Louis Public Radio (Oct. 28, 2025)
............................................................................................................................... 722a
Stipulated Exhibit 15 – Jason Rosenbaum, Group asks judge to force Missouri
secretary of state to decide redistricting referendum, St. Louis Public Radio
(May 18, 2026) ...................................................................................................... 731a
Stipulated Exhibit 16 – Kacen Bayless, Is Missouri GOP dragging out redistricting
cases? ‘Delay works in our favor’, Kansas City Star (Jan. 8, 2026) ................... 736a
Stipulated Exhibit 17 – 1922 Election Results for Proposition 17 ........................ 740a
Stipulated Exhibit 18 – Newspaper Articles Regarding the Attempted 1922
Referendum Election on Congressional Redistricting ........................................ 744a
Stipulated Exhibit 19 – Newspaper Articles Regarding the Attempted 1952
Referendum Election on Congressional Redistricting ........................................ 748a
Volume III
Stipulated Exhibit 20 – House Bill 2909 (2022) ..................................................... 752a
Stipulated Exhibit 21 – Affidavit of Brianna Lennon (Aug. 13, 2026) .................. 904a
Stipulated Exhibit 22 –Motion to Expedite, State ex rel. People Not Politicians v.
Limbaugh, No. WD88821 (Mo. Ct. App. April 1, 2026). ..................................... 908a
Stipulated Exhibit 23 –Suggestions in Support of Petition for a Writ of Prohibition,
State ex rel. People Not Politicians v. Limbaugh, No. WD88821 (Mo. Ct. App. April
1, 2026). ................................................................................................................ 912a
Stipulated Exhibit 24 –Motion to Expedite Appellate Proceedings, Luther v.
Hoskins, No. SC101412 (Mo. Dec. 31, 2025) ....................................................... 924a
Stipulated Exhibit 25 – Plaintiffs’ Suggestions in Opposition to Continue Trial
Setting, Wise v. State, No. 2516-CV29597 (Jackson Cnty. Cir. Ct. Dec. 15, 2025)
............................................................................................................................... 929a
Stipulated Exhibit 26 – Plaintiffs’ Suggestions in Support of Motion for Preliminary
Injunction and Consolidation with Hearing on Merits, Maggard v. State,
No. 25AC-CC09120 (Cole Cnty. Cir. Ct. Jan. 14, 2026) ..................................... 938a
Stipulated Exhibit 27 – Brief of Respondent Denny Hoskins, Luther v. Hoskins, No.
SC101412 (Mo. Feb. 9, 2026) ............................................................................... 960a
Stipulated Exhibit 28 – Affidavit of Tammy Brown (Aug. 13, 2026)................... 1023a
Stipulated Exhibit 29 –Brief of Amicus Curiae Brianna Lennon, County Clerk &
Election Authority of Boone County in Support of Appellants, Maggard v. State,
No. SC101581 (Mo. April 10, 2026) ................................................................... 1029a
Stipulated Exhibit 30 – Brief of Amici Curiae St. Charles County Director of
Elections Kurt Bahr, in his personal capacity, the American Redistricting Project,
and Restoring Integrity and Trust in Elections in Support of
Defendants-Respondents, Maggard v. State, No. SC101581 (Mo. April 28, 2026)
............................................................................................................................. 1050a
Volume IV
Stipulated Exhibit 31 – Transcript Excerpts, Wise v. State, No. 2516-CV29597
(Jackson Cnty. Cir. Ct. Feb. 19, 2026)............................................................... 1082a
Stipulated Exhibit 32 – Mathew Pilger, Missouri’s New Congressional Map Could
Complicate Midterm Voting Clerks Warn, Missourinet (Sept. 15, 2025) ......... 1228a
Stipulated Exhibit 33 – Jen Rice & Yunior Rivas, Missouri Block’s anti-gerrymander
referendum from November ballot in attempt to silence voters, Democracy Docket
(Aug. 4, 2026)...................................................................................................... 1235a
Stipulated Exhibit 34 – Jen Rice, GOP derails bid to stop Missouri gerrymander for
2026, Democracy Docket (Mar. 27, 2026) .......................................................... 1242a
Stipulated Exhibit 35 – Affidavit of Republican National Committee (Aug. 13, 2026)
............................................................................................................................. 1248a
Stipulated Exhibit 36 – Affidavit of Executive Director of Missouri Republican State
Committee (Aug. 11, 2029) ................................................................................ 1253a
Stipulated Exhibit 37 – Affidavit of Deputy General Counsel of National Republican
Congressional Committee (Aug. 17, 2026) ........................................................ 1259a
Trial Transcript
(August 19, 2026) ............................................................................................... 1264a
Volume V
Appellant’s Brief in the Missouri Supreme Court
(August 25, 2026) ............................................................................................... 1335a
Respondent’s Brief in the Missouri Supreme Court
(August 27, 2026) ............................................................................................... 1442a
Intervenors-Respondents’ Brief in the Missouri Supreme Court
(August 27, 2026) ............................................................................................... 1519a
Appellant’s Reply Brief in the Missouri Supreme Court
(August 30, 2026) ............................................................................................... 1605a
Motion for a Stay of Injunction Pending Emergency Appeal and Application for Stay
to the Supreme Court of the United States
(September 4, 2026) ........................................................................................... 1639a
Declaration of Denny Hoskins in Support of Respondent’s Motion for a Stay Pending
Appeal
(September 3, 2026) ........................................................................................... 1664a
Declaration of Christoper Brundick in Support of Applicant’s Motion for a Stay
Pending Appeal
(September 4, 2026) ...........................................................................................1669A
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No. SC101805
Circuit Court of Cole County Case Number 26AC-CC00440
In the Supreme Court of Missouri
September Session, 2026
Richard von Glahn,
Appellant,
v. APPEAL FROM THE CIRCUIT COURT OF COLE COUNTY
Denny Hoskins, in His Official Capacity, et al.,
Respondents.
Now at this day come again the parties aforesaid, by their respective attorneys, and the
Court here being now sufficiently advised of and concerning the premises, doth consider and
adjudge that the judgment aforesaid, in form aforesaid, by the said Cole County Circuit Court
rendered, be reversed, annulled and for naught held and esteemed, and that the said Appellant be
restored to all things which he has lost by reason of said judgment in conformity with the opinion
of this Court herein delivered; and that the said Appellant recover against the said Respondents
costs and charges herein expended, and have execution therefor.
.
(Opinion filed.)
STATE OF MISSOURI-Sct.
I, BETSY LEDGERWOOD, Clerk of the Supreme Court of the State of Missouri, certify
that the foregoing is a full, true and complete transcript of the judgment of said Supreme Court,
entered of record at the September Session thereof, 2026, and on the 3rd day of September, 2026,
in the above entitled cause.
Given under my hand and seal of said Court at the City of
Jefferson, this 3rd day of September, 2026.
Clerk
Deputy Clerk
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Supreme Court of Missouri
SC101805
September 4, 2026
Richard Von Glahn,
Appellant,
vs.
Denny Hoskins, In His Official Capacity, et al.,
Respondents.
Order
Respondent’s motion for a stay of injunction pending emergency appeal and application for stay
to the Supreme Court of the United States overruled.
By:
Chief Justice
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26AC-CC00440
IN THE CIRCUIT COURT OF COLE COUNTY, MISSOURI
RICHARD VON GLAHN
Plaintiff,
v.
DENNY HOSKINS, in his official
capacity,
Defendant.
)
)
)
)
)
)
)
)
)
)
Case No. 26AC-CC00248
PETITION FOR DECLARATORY JUDGMENT AND INJUNCTIVE
RELIEF UNDER SECTION 116.200
Plaintiff Richard von Glahn for his Petition, alleges and states as follows.
1.
Plaintiff Richard von Glahn is a Missouri citizen, resident of St. Louis
County, a taxpayer, and qualified voter in the State of Missouri.
2.
Plaintiff von Glahn is the proponent of the referendum that is the
subject of this action.
3.
Defendant Denny Hoskins is the Secretary of State for the State of
Missouri. His principal office is in Cole County, Missouri.
4.
Missourians reserved to themselves the “power to approve or reject
by referendum any act of the general assembly, except as hereinafter provided.”
Mo. Const. art. III, § 49.
5.
Article III, Section 52(a) of the Constitution identifies the sole
exceptions to the people’s referendum right: (i) “laws necessary for the immediate
preservation of the public peace, health or safety” and (ii) “laws making
appropriations for the current expenses of the state government, for the
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SC101805 Appeal Document Number 2 Page 1
maintenance of state institutions and for support of public schools.” Mo. Const.
art. III, § 52(a).
6.
To place a referendum petition before voters, a proponent must gather
signatures of “five percent of the legal voters in each of two-thirds of the
congressional districts in the state[.]” Mo. Const. art. III, § 52(a).
7.
For an election taking place in 2026, a proponent must gather 106,384
signatures across six congressional districts.1
8.
On September 12, 2025, the General Assembly truly agreed and finally
passed—during a special session—House Bill 1 (“HB 1”) titled: “An Act To repeal
sections 128.345, and 128.348, RSMo, and to enact in lieu thereof twelve new
sections relating to the composition of congressional districts.”
9.
Attached as Exhibit 1 is a true and correct copy of HB 1.
10.
HB 1 is an act of the General Assembly.
11.
HB 1 is not a law necessary for the immediate preservation of the
public peace, health, or safety.
12.
The General Assembly did not attach an emergency clause to HB 1.
13.
HB 1 is not a law making appropriations for the current expenses of
the state government, for the maintenance of state institutions, or for support of
public schools.
1 See
https://www.sos.mo.gov/CMSImages/Elections/Petitions/MakeYourVoiceHeard
_02.07.2025.pdf
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14.
On October 15, 2025, Defendant Hoskins, the “General Assembly” and
the State of Missouri filed a lawsuit against Plaintiff in federal court, denominated
Missouri General Assembly v. von Glahn, No. 25-cv-01535 (E.D. Mo.).
15.
That lawsuit sought to prevent Plaintiff from turning in signatures on
the Referendum.
16.
Attached as Exhibit 2 is a copy of the Complaint filed in the federal
action.
17.
Defendant claimed Plaintiff should not be permitted to turn in
signatures because initiating a referendum on a redistricting bill would “violate[]
both the U.S. and Missouri Constitutions.” Ex. 3 at 2.
18.
Defendant Hoskins’ position in his filings was that the referendum
would violate the Missouri Constitution regardless of the number of signatures
submitted.
19.
Defendant Hoskins’ position in his filings was that the referendum
would violate the U.S. Constitution regardless of the number of signatures
submitted.
20.
Following expedited litigation, including Defendant seeking a
preliminary injunction, the federal court issued a decision dismissing the federal
lawsuit on December 8, 2025.
21.
Attached as Exhibit 3 is a copy of the decision in the federal action.
22.
On December 9, 2025, Plaintiff submitted more than 300,000
signatures in support of the Referendum to the Secretary’s Office.
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23.
The Secretary accepted the Referendum for filing and issued a receipt
for 691 boxes of signatures.
24.
Each referendum petition page Plaintiff submitted to Defendant
Hoskins was identical to the form approved by his office on October 14, 2025.
25.
Attached hereto as Exhibit 4 is a true and correct copy of the October
14, 2025 approval of the referendum petition as to form.
26.
Each referendum petition page submitted to Defendant Hoskins
included a completed and signed circulator’s affidavit.
27.
By statute, Defendant Hoskins is required to “examine the
[Referendum] to determine whether it complies with the Constitution of Missouri
and with this chapter [116].” § 116.120.1, RSMo.
28.
In doing so, Defendant Hoskins “may rely on the circulator’s affidavit
found on each page of the petition as required by section 116.080 and 116.130.1, or
[he] may verify the petition signatures by use of random sampling.”
29.
“Based on this sampling, [Defendant Hoskins] can approve or reject
the petition signatures or proceed to a verification of all the signatures.”
30.
“With or without sampling, [Defendant Hoskins] has discretion to
order the local election authorities to verify all the signatures.”
31.
Chapter 116 requires Defendant Hoskins to issue a certificate deeming
the Referendum sufficient or insufficient, which decision is subject to review by the
courts.
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32.
Chapter 116 gave Defendant Hoskins until August 4, 2026 to issue
such certificate.
33.
On August 4, 2026, Defendant issued a certificate of insufficiency for
the Referendum pursuant to § 116.150, RSMo.
34.
Attached as Exhibit 5 is a copy of Defendant Hoskins’ certificate of
insufficiency.
35.
Defendant Hoskins is required to “stat[e] the reason for the
insufficiency.” § 116.150.2, RSMo.
36.
The only reason for insufficiency identified in Defendant Hoskins’
certificate is his assertion that the referendum violates the Missouri and U.S.
Constitutions. See Ex. 5.
37.
By law, no changes can be made to the November general election
ballots after September 8, 2026. See § 115.125.3, RSMo.
38.
Plaintiff filed this Petition within 10 days of Defendant Hoskins
issuing the certificate of insufficiency.
39.
Plaintiff’s challenge to that certificate is therefore timely. § 116.200.1,
RSMo.
PLAINTIFF IS ENTITLED TO AN INJUNCTION
40.
Plaintiff has no adequate remedy at law.
41.
Plaintiff will face irreparable harm absent an order enjoining the
Secretary of State from further implementing or using the congressional districts
contained in HB 1.
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42.
Plaintiff is the proponent of the referendum petition and he is entitled
to the immediate suspension of the use and implementation of HB 1.
43.
Plaintiff’s referendum right will be undermined if the Secretary is
allowed to further implement or make use of HB 1.
44.
The Secretary faces no harm because the his duty is to carry out the
election laws of Missouri and he should have no preference for which congressional
districts are used.
45.
The public interest is served by restraining the Secretary from taking
further steps to implement or use the congressional districts in HB 1 to ensure that
the referendum right is fully realized and that the correct congressional districts
are utilized to conduct the 2026 general congressional election.
COUNT I:
THE REFERENDUM IS SUFFICIENT
46.
Plaintiff incorporates the preceding allegations as if set forth fully
herein.
47.
The Missouri Constitution requires that referendum petitions be
“signed by five percent of the legal voters in each of two-thirds of the congressional
districts in the state.” Mo. Const. art. III, § 52(a).
48.
The Referendum was signed by the constitutionally required number
of legal voters in each of two-thirds of Missouri’s congressional districts.
49.
Defendant Hoskins did not identify the number of signatures
gathered as a reason for deeming the Referendum insufficient. See Ex. 5.
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50.
Defendant Hoskins instead contends the Missouri and U.S.
Constitutions prohibit subjecting a redistricting bill to the referendum.
51.
They do not.
52.
The Missouri Constitution identifies only two categories of bills
exempt from the referendum: (1) bills addressing specified emergencies and (2)
specified appropriations bills. Mo. Const. art. III, § 52(a).
53.
HB 1 falls into neither of those categories.
54.
The Referendum does not violate the Missouri Constitution and it is
sufficient.
55.
Like the Missouri Constitution, the U.S. Constitution does not
prohibit a state from subjecting a redistricting bill to the referendum.
56.
Just three years ago, the Supreme Court “embraced the core principle
espoused in Hildebrant and Smiley that redistricting is a legislative function, to be
performed in accordance with the State’s prescriptions for lawmaking, which may
include the referendum and the Governor’s veto.” Moore v. Harper, 600 U.S. 1, 25
(2023) (quotations omitted).
57.
The Court squarely “rejected the contention that the Elections Clause
vests state legislatures with exclusive and independent authority when setting the
rules governing federal elections.” Id. at 26.
58.
Put simply: “A state legislature may not create congressional districts
independently of requirements imposed by the state constitution with respect to
the enactment of laws.” Id. at 26 (quotations omitted).
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59.
All laws, except for emergency laws and appropriations, are subject to
the referendum under the Missouri Constitution.
60.
The Referendum does not violate the U.S. Constitution and it is
sufficient.
61.
Plaintiff is entitled to an order reversing Defendant Hoskins’
certification decision.
WHEREFORE, Plaintiff prays that this Court:
a.
Enter judgment in favor of Plaintiff and reversing Defendant
Hoskins’ certification decision;
b.
Restrain Defendant and those acting in concert with him from
taking any further steps to implement or mandate the use of
HB 1; and
c.
Grant such other and further relief as the Court deems just
and proper.
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Respectfully submitted,
STINSON LLP
/s/ Charles W. Hatfield
Charles W. Hatfield, No. 40363
Alexander C. Barrett, No. 68695
Alixandra S. Cossette, No. 68114
Greta M. Bax, No. 73354
230 W. McCarty Street
Jefferson City, Missouri 65101
Phone: (573) 636-6263
Fax: (573) 556-3632
chuck.hatfield@stinson.com
alexander.barrett@stinson.com
alix.cossette@stinson.com
greta.bax@stinson.com
ATTORNEYS FOR PLAINTIFFS
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26AC-CC00440
Exhibit 1
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SC101805 Appeal Document Number 3 Page 1
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Case: 4:25-cv-01535
Doc. #: 1
Filed: 10/15/25
Page: 1 of 24 PageID #: 1
IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF MISSOURI
EASTERN DIVISION
MISSOURI GENERAL ASSEMBLY,
DENNY HOSKINS, IN HIS OFFICIAL
CAPACITY AS MISSOURI SECRETARY OF
STATE,
&
STATE OF MISSOURI,
Plaintiffs,
v.
Case No.
RICHARD VON GLAHN
&
PEOPLE NOT POLITICIANS,
Defendants.
COMPLAINT
Plaintiffs, the Missouri General Assembly, Missouri Secretary of State Denny
Hoskins, and the State of Missouri, for their Complaint respectfully allege as follows:
INTRODUCTION
1.
The U.S. Constitution expressly vests the power to apportion federal
congressional districts in the state legislatures, with only Congress itself expressly given
oversight authority over state legislatures. U.S. Const. art. I, § 4, cl. 1. Yet in Missouri,
Defendants, Richard von Glahn and People Not Politicians, have initiated a referendum
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SC101805 Appeal Document Number 3 Page 2
Case: 4:25-cv-01535
Doc. #: 1
Filed: 10/15/25
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process that would strip the General Assembly of its authority over redistricting. This
unprecedented act violates both the U.S. and Missouri Constitutions.
2.
Just two years ago, the U.S. Supreme Court reaffirmed the core authority of
state legislatures to draw congressional districts for the U.S. House of Representatives.
The court emphasized how other state-governmental actors “do not have free rein” to
transgress state legislatures’ authority to apportion congressional districts. Moore v.
Harper, 600 U.S. 1, 34 (2023). For good reason: The U.S. Constitution’s Elections Clause
uniquely bestows on state legislatures the power to set the times, places, and manner of
federal elections, including reapportionment authority—with only Congress itself being
the enumerated overseer of legislatures’ actions. See U.S. Const. art. I, § 4, cl. 1.
3.
Despite that constitutional language, some state constitutions have expressly
transferred authority over federal redistricting from state legislatures to other entities—
like independent redistricting commissions. See, e.g., Ariz. State Leg. v. Ariz. Indep.
Redistricting Comm’n, 576 U.S. 787, 796–98 (2015). Jurists have disagreed on whether
such delegations are constitutional. See id. at 826 (Roberts, C.J., dissenting).
4.
This case does not require this Court to revisit that debate. Where the U.S.
Constitution expressly vests authority in a particular actor, that authority cannot be
taken away without a clear and express statement. See Moore, 600 U.S. at 34–36. In
Arizona State Legislature, for example, the Arizona Constitution did “directly and
immediately” transfer the Arizona’s Legislature’s authority over redistricting to another
entity. 576 U.S. at 801. And in State of Ohio ex rel. Davis v. Hildebrant, the Supreme
Court considered a federal constitutional challenge under the Guarantee Clause to
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Case: 4:25-cv-01535
Doc. #: 1
Filed: 10/15/25
Page: 3 of 24 PageID #: 3
Ohio’s redistricting scheme only after concluding that state law “ma[de] it clear” that the
legislature had been partially divested of its authority over federal redistricting. 241
U.S. 565, 567–68 (1916) (holding it was “obvious” that state law was “conclusive” on that
point).
5.
Such clear-statement rules are fixtures of American constitutional law because
they ensure that the relevant governmental actors actually intended to push the
boundaries and potentially upset the careful balances struck by the U.S. Constitution’s
Framers.
See West Virginia v. EPA, 597 U.S. 697, 736–37 (2022) (Gorsuch, J.,
concurring); Amy Coney Barrett, Substantive Canons and Faithful Agency, 90 B.U. L.
Rev. 109, 166–67 (2010). For example, even though the Constitution vests legislative
power in Congress, courts allow Congress to delegate major policy decisions to the
Executive Branch—but only if Congress provides a clear statement of authority. West
Virginia, 597 U.S. at 723; id. at 746–49 (Gorsuch, J., concurring); Paul v. United States,
140 S. Ct. 342, 342 (2019) (statement of Kavanaugh, J., respecting denial of certiorari).
Similarly, courts demand a clear statement before assuming Congress intended to
legislate in areas of traditional state authority—to protect the U.S. Constitution’s
commitment to federalism. See Sackett v. EPA, 598 U.S. 651, 679–80 (2023); Gregory v.
Ashcroft, 501 U.S. 452, 460 (1991).
6.
Defendants cannot identify any language that “makes it clear” that the
Missouri Constitution transfers authority over federal redistricting away from the
General Assembly. Hildebrant, 241 U.S. at 568. While Missouri has chosen to allow
voters to revisit legislation passed by the General Assembly, nothing in the Missouri
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Constitution expressly says that federal congressional reapportionment may be
subjected to a referendum. See Mo. Const. art. III, §§ 49, 52(a). In other words, the
people of Missouri have never made the conscious choice to undermine the Framers’
decision to vest this State’s legislature with the reapportionment authority.
7.
Defendants therefore have no legal basis to proceed with their referendum.
This Court should declare that such a referendum would violate both the U.S. and
Missouri Constitutions.
PARTIES
I.
Plaintiffs
8.
Plaintiff Missouri General Assembly is the legislative branch of Missouri’s
government. See Mo. Const. art. III, § 1. The People of Missouri directly elect the
General Assembly.
9.
Plaintiff Denny Hoskins is the Missouri Secretary of State.
10.
Plaintiff State of Missouri is a sovereign State of the United States of America.
11.
Plaintiffs bring this action to prevent Defendants Richard von Glahn and
People Not Politicians from unconstitutionally usurping the General Assembly’s vested
authority to reapportion the State of Missouri’s congressional representation.
12.
Plaintiffs come to this Court asking for an order barring Defendants from
seeking to overturn the General Assembly’s reapportionment of Missouri’s congressional
representation via a statewide referendum, a direct imposition on the General
Assembly’s authority under Article I, § 4, cl. 1, of the U.S. Constitution, and Article III,
§ 45 of the Missouri Constitution.
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States and legislatures can seek, in the federal courts, to protect the
congressional-apportionment authority—a power vested in the state legislatures by
Article I, § 4, cl. 1, of the U.S. Constitution. See, e.g., Ariz. State Leg., 576 U.S. at 803–
04.
14.
Plaintiffs sue to prevent the dedication of the State’s resources to a referendum
whose aim is unconstitutional and at odds with the General Assembly’s vested authority
over federal congressional reapportionment.
15.
Plaintiffs need not wait for the outcome of the referendum before seeking to
protect the General Assembly’s exercise of authority under Article I, § 4, cl. 1, of the U.S.
Constitution. With the initiative process already commenced, the State must presently
expend its resources on an initiative whose aim is unlawful.
II.
Defendants
16.
Defendant Richard von Glahn is a natural person seeking to commence a
referendum that would overturn the General Assembly’s latest reapportionment of
Missouri’s congressional representation.
17.
Mr. von Glahn submitted a referendum petition challenging the General
Assembly’s recent redistricting bill to the Secretary of State.
18.
On information and belief, Mr. von Glahn resides and has engaged in actions
pertaining to his pursuit of the referendum at 9 Wilshire Terrace, Webster Grove, MO
63119.
19.
On information and belief, Mr. von Glahn is the Executive Director of
Defendant People Not Politicians.
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Defendant People Not Politicians is an organization dedicated to, among other
things, opposing the Missouri General Assembly’s actions regarding reapportionment. 1
21.
On information and belief, Defendant People Not Politicians is a non-profit
political and advocacy organization operating within the State of Missouri.
22.
On information and belief, Defendant People Not Politicians is soliciting
donations from politically progressive individuals and organizations from around the
country to fund its referendum efforts.
JURISDICTION AND VENUE
23.
This Court has subject matter jurisdiction over the federal claims under 28
U.S.C. § 1331 because a provision of the U.S. Constitution governs the disposition of this
case.
24.
This Court has supplemental jurisdiction over the state-constitutional claim
under 28 U.S.C. § 1367.
25.
This Court has the authority to issue the requested declaratory relief under 28
U.S.C. §§ 2201–2202 and this Court’s inherent equitable authority.
26.
This Court has personal jurisdiction over Defendant Richard von Glahn
because, on information and belief, Mr. von Glahn resides and has engaged in actions
pertaining to this case at 9 Wilshire Terrace, Webster Grove, MO 63119.
27.
Venue is proper in this judicial district under 28 U.S.C. § 1391(b) because
Defendant Richard von Glahn resides and has undertaken efforts to secure an unlawful
referendum within this District and the Eastern Division.
1 See People Not Politicians, https://peoplenotpoliticiansmo.org/#about.
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Exercising specific personal jurisdiction over Defendant People Not Politicians
is proper under the Due Process Clause because Defendant has such a deep and systemic
presence in Missouri that it can reasonably foresee being sued in Missouri. See Ford
Motor Co. v. Mont. Eighth Judicial Dist. Court, 592 U.S. 351, 364–65 (2021).
29.
Venue is proper in this judicial district under 28 U.S.C. § 1391(b) respecting
People Not Politicians because Plaintiffs allege that the Defendant has undertaken
efforts to secure an unlawful referendum within this District and Division.
FACTS COMMON TO ALL COUNTS
I.
The General Assembly
Representation.
30.
Reapportions
Missouri’s
Congressional
On August 29, 2025, Missouri’s Governor called a special session of the General
Assembly to, among other things, “enact legislation establishing updated congressional
districts.” 2
31.
The General Assembly convened its special session in September, with the
House of Representatives opening the session on September 3, 2025. The House of
Representatives approved the new apportionment on September 9, 2025.
32.
The Missouri Senate concurred and passed the redistricting bill on September
12, 2025.
33.
The Missouri Governor signed the redistricting bill on September 28, 2025.
2 Governor Kehoe Announces Special Session on Congressional Redistricting
and Initiative Petition Reform, Off. of Gov. Mike Kehoe (Aug. 29, 2025),
https://governor.mo.gov/press-releases/archive/governor-kehoe-announces-specialsession-congressional-redistricting-and.
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Defendants Initiate Their Effort to Subject the Reapportionment to a
Referendum.
34.
In Missouri, citizens can seek “to approve or reject” legislation by the General
Assembly via a referendum. Mo. Const. art. III, § 49; see also Ariz. State Leg., 576 U.S.
at 794 (explaining how “the referendum serves as a negative check” by voters on the
legislature’s actions).
35.
Doing so first requires submitting a petition to the Plaintiff Secretary of State
for review. See Mo Rev. Stat. § 116.332.1. The Secretary has limited discretion to reject
the proposal. See id.
36.
Following review by the Secretary, the petition must garner “five percent of
legal voters in each of two-thirds of congressional districts in the state.” Mo. Const.
art. III, § 52(a). If a petition receives the necessary signatures, the challenged law
cannot take effect until a referendum occurs. Id. § 52(b).
37.
After the passage of the new congressional map, but before the Governor
signed the reapportionment into law, Defendants began their efforts to subject the new
map to a citizen referendum. 3
38.
On September 12, 2025, Defendants submitted their petition for a referendum
to the Secretary of State.
See Jason Hancock, Three Lawsuits and a Referendum: New Missouri
Congressional Map Faces Multiple Attacks, Mo. Indep. (Sept. 15, 2025),
https://missouriindependent.com/2025/09/15/three-lawsuits-and-a-referendum-newmissouri-congressional-map-faces-multiple-attacks/.
3
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In a public statement, Mr. von Glahn made the initiative’s aim clear: “The
people who are going to put this issue on the ballot are Missourians. The people who are
going to have the final say on this are Missourians.” 4
40.
Similarly, Defendant People Not Politicians expressed its intentions of
pursuing a referendum.
It called the reapportionment “an illegal gerrymandering
scheme that is nothing more than an unconstitutional power grab.” 5 It then said, in no
uncertain terms, “We believe that Missouri voters—not politicians—should have the final
say. We have filed a citizen’s referendum to gather signatures to put this unjust map
before voters on an upcoming ballot.” 6
41.
The organization then asks visitors of its website to “Donate Now”—without
limiting the request solely to Missouri voters or residents. 7
42.
Defendants have already seen great success in securing support and resources
from out-of-state partisan special interests.
Notably, the Democratic National
Committee has promised to devote staff and monetary support to the referendum. 8
4 Charlie Keegan, Opponents to Missouri Redistricting Identify 2 Paths to Block
Bill, KSHB 41 (Sept. 15, 2025), https://www.kshb.com/news/local-news/opponents-toredistricting-going-down-2-paths-to-block-bill.
5 People Not Politicians, supra note 1.
6 Id. (emphasis in original).
7 Id.
Jason Rosenbaum, Democratic National Committee Will Contribute to
Blocking Missouri Congressional Map, St. Louis Pub. Radio (Sept. 29, 2025),
https://www.stlpr.org/government-politics-issues/2025-09-29/democratic-nationalcommittee-will-contribute-to-blocking-missouri-congressional-map.
8
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Plaintiffs’ Ongoing Commitments Regarding the Initiative.
43.
Because Defendants have initiated the referendum process, the Secretary of
State in particular and the State in general are currently being forced to commit
resources in response.
44.
Defendants’ filing a petition seeking a referendum triggers several ongoing
responsibilities that will force the committal of resources by the Secretary of State and
the State as a whole. The process begins with submission of a “sample sheet” of the
initiative to the Secretary of State. Mo Rev. Stat. § 116.332.1. Missouri law requires the
Secretary and the Attorney General to “review the petition for sufficiency as to form and
approve or reject the form of the petition, stating the reasons for rejection, if any.” Id.
The Secretary also refers the petition to the State Auditor “for purposes of preparing a
fiscal note and fiscal note summary.” Id. The Secretary must post the proposed measure
on State’s website within two business days of receipt. Id. § 116.332.2. The Secretary
has fifteen days to review the petition. Id. § 116.332.4. As noted, Defendants have
already filed their sample sheet with the Secretary.
45.
Even before the Secretary issued a decision on the form of the proposed
referendum, Defendants sued over the Secretary’s review process. See Pet., People Not
Politicians v. Hoskins, 25AC-CC07128 (Cir. Ct. Cole Cnty. Sept. 18, 2025). The State is
currently being forced to expend substantial resources litigating that case.
46.
A host of new obligations occurs when a proponent submits a final petition with
signatures to the Secretary of State. All of these will force the Secretary to reallocate
scarce resources and personnel to handling the referendum petition. First, the Secretary
will need to “examine the petition to determine whether it complies with the Constitution
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of Missouri and with this chapter.” Id. § 116.120.1. Second, responsibility for verifying
signatures falls with the Secretary. See id. § 116.120. The Secretary may also involve
election authorities in checking signatures. See id. § 116.130. Once the Secretary makes
a determination regarding whether a petition has received the necessary number of nonfraudulent signatures, he must then issue a certificate of sufficiency or insufficiency. See
id. § 116.150.
In the latter case, the Secretary must detail “the reason for the
insufficiency.” Id. § 116.150.2. Time limits govern when the Secretary must make a
decision. See id. § 116.150.3.
47.
Even if the Secretary finds a petition sufficient, the resource commitments do
not end. Missouri law requires the State to hold a public hearing and take comments on
any petition deemed to have sufficient signatures. See id. § 116.153. The Secretary will
then be responsible for preparing the ballot initiate. See id. § 116.220.
48.
If a referendum petition gains enough signatures to qualify for a vote before
the people, the challenged law is frozen pending the public vote. Mo. Const. art. III,
§ 52(b). Thus, the General Assembly loses its authority over redistricting pending that
public vote. And the entire State would be plunged into legal uncertainty over which
legislative maps would govern Missouri elections in 2026.
49.
Given these state-law requirements, the Secretary of State and the State as a
whole are currently forced to expend resources facilitating a referendum initiative that
they believe unconstitutionally deprives the General Assembly of its vested and
previously undisturbed authority to reapportion the State’s federal congressional
representation. This creates a sufficient injury-in-fact for justiciability purposes. See,
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e.g., New York v. U.S. Dep’t of Homeland Sec., 969 F.3d 42, 59–60 (2d Cir. 2020) (holding
“States’ alleged economic harms are sufficiently concrete and imminent to constitute
injury in fact” for preliminary injunction); City of Chicago v. Matchmaker Real Estate
Sales Ctr., Inc., 982 F.2d 1086, 1095 (7th Cir. 1992) (holding that the government
plaintiff had standing because of its legally required committal of resources); see also
Axon Enter., Inc. v. FTC, 598 U.S. 175, 191 (2023) (explaining that “here-and-now injury”
occurs when the plaintiff alleges being subjected to an unconstitutional process); Ariz.
State Leg., 576 U.S. at 800–01 (explaining that government need not first violate the law
to gain standing); BTS Holdings, LLC v. OSHA, 17 F.4th 604, 618 (5th Cir. 2021)
(explaining that “the diversion of resources” and burdens on the State’s constitutionally
granted role qualify as irreparable harms).
Likewise, an order from this Court
confirming that Defendants’ proposed referendum is unconstitutional and enjoining
their actions would redress the harms alleged here. See Ariz. State Leg., 576 U.S. at 800
(recognizing as much and concluding that the case met standing and ripeness
requirements).
50.
Plaintiffs also do not need to wait for any future actions by Defendants. As
noted, Defendants have already filed their sample sheet with the Secretary of State—
the first step in the initiative process, and Defendants are litigating the manner in which
the Secretary handled their first sample sheet.
While that litigation is ongoing,
Defendants submitted an additional sample sheet, which the Secretary of State approved
as to form, thus ensuring the referendum process will continue. See Ohio Civil Rights
Comm’n v. Dayton Christian Schs., Inc., 477 U.S. 619, 625 n.1 (1986) (recognizing that
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the filing of an administrative action threatening harm to the plaintiffs’ interests shows
that the controversy is ripe). Hence, Defendants will continue forcing the State to
allocate resources on the referendum per the governing statutes, and through their
ongoing litigation against the Secretary of State. These resource expenditures should
not occur because the referendum’s ultimate aim—depriving the General Assembly of its
vested authority without a clear statement—is unconstitutional. See Neb. Pub. Power
Dist. v. MidAm. Energy Co., 234 F.3d 1032, 1039–40 (8th Cir. 2000) (recognizing a claim
was ripe because of the hardship that delay would impose).
IV.
The Effort at a Ballot Initiative Has Violated, Is Violating, and Will
Continue to Violate, the Federal and Missouri Constitutions.
51.
Absent a clear statement in the Missouri Constitution transferring the
apportionment power from the General Assembly to a ballot referendum, Defendants
cannot proceed with their referendum. The Elections Clause provides that, as an initial
matter, the “Times, Places and Manner of holding Elections for Senators and
Representatives, shall be prescribed in each State by the Legislature thereof.” U.S.
Const. art. I, § 4, cl. 1. The General Assembly’s “vested authority is not just the typical
legislative power exercised pursuant to a state constitution.
Rather, when a state
legislature enacts statutes governing [federal] elections, it operates ‘by virtue of a direct
grant of authority’ under the United States Constitution.” Carson v. Simon, 978 F.3d
1051, 1060 (8th Cir. 2020) (per curiam).
52.
In choosing to specifically entrust state legislatures with authority over federal
congressional redistricting, the Framers of the U.S. Constitution ensured that such
power would be exercised by officials “accountable by the people for the rules they write
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or fail to write.” Democratic Nat’l Comm. v. Wis. State Leg., 141 S. Ct. 28, 29 (2020)
(Gorsuch, J., concurring in denial of application to vacate stay). They also ensured that
redistricting decisions would reflect “the collective wisdom of the whole people”—as
expressed through the people’s elected representatives. Id.
53.
While the U.S. Supreme Court has recognized that express state constitutional
amendments can divest legislatures of their apportionment power, the court has never
held that a general referendum provision can curtail the legislature’s exercise of that
authority. See Ariz. State Leg., 576 U.S. at 814 (holding that a State can adopt an express
constitutional provision transferring the legislature’s apportionment authority to an
independent commission). Because the Framers of the Federal Constitution made “a
deliberate choice” to vest reapportionment power in state legislatures, other state actors
cannot use the vagaries of state law to transfer that power elsewhere. Moore, 600 U.S.
at 34. Hence, state law must plainly circumscribe the legislature’s federal congressionalapportionment authority. Cf. id. at 34–36 (holding that state “courts do not have free
rein” to intrude upon the legislature’s apportionment power absent “a fair reading” of
state law limiting the power); Carson, 978 F.3d at 1060 (discussing how state officials
cannot “override” the state legislature’s exercise of power under the Elections Clause).
54.
Moreover, serious constitutional doubt persists about whether state-ballot
initiatives can ever divest state legislatures of their congressional-apportionment
authority. The “text, structure, or history of the Constitution” plainly show that Article
I, Section 4 deliberately vests “the ‘Legislature,’” not “‘the people’” with the power to
reapportion congressional representation. Ariz. State Leg., 576 U.S. at 825 (Roberts,
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C.J., dissenting). “Direct lawmaking by the people was ‘virtually unknown when the
Constitution of 1787 was drafted.’” Id. at 793 (majority opinion). And the U.S. Supreme
Court has never upheld the use of a ballot referendum to nullify a legislature’s
congressional reapportionment against an Elections Clause challenge. See id. at 840
(Roberts, C.J., dissenting) (explaining how the only instance where the Supreme Court
considered the use of such a referendum was in the context of a Guarantee Clause
challenge in Hildebrant). 9
55.
Clear-statement rules are fixtures of American law where doubt persists
regarding the exercise of authority under the U.S. Constitution. For example, the U.S.
Supreme Court declined to find that Congress intended to use its power under the
Commerce Clause to impose employment regulations on state-government officials when
the federal statute did not expressly say that it applied to state officers. See Gregory,
501 U.S. at 464. The Court mandated a clear statement from Congress despite a prior
holding that Congress possessed authority to regulate state employees. See id. (citing
Garcia v. San Antonio Metro. Transit Auth., 469 U.S. 528 (1985)). Likewise, given nondelegation concerns, the Supreme Court has long required that administrative agencies
point to a specific grant of statutory authority before exercising some significant
authority. See West Virginia, 597 U.S. at 721 (“[O]ur precedent teaches that there are
9 Plaintiffs preserve their argument that Arizona Independent Redistricting
Commission was wrongly decided, and thus should be overruled. See, e.g., Ariz. State
Leg., 576 U.S. at 825 (Roberts, C.J., dissenting). However, even under that precedent,
this Court can grant Plaintiffs all requested relief. Plaintiffs also preserve their
argument that even if there is no clear-statement rule (or that it is satisfied), this
case is distinguishable from Arizona Independent Redistricting Commission.
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‘extraordinary cases’ that call for a different approach—cases in which the ‘history and
the breadth of the authority that [the agency] has asserted,’ and the ‘economic and
political significance’ of that assertion, provide a ‘reason to hesitate before concluding
that Congress’ meant to confer such authority.” (second alteration in original)); see also
id. at 740 (Gorsuch, J., concurring) (explaining the doctrine’s history).
56.
The reasons for demanding a clear statement in the Missouri Constitution
apply with equal force to the assertion that the referendum process permits usurping
the General Assembly’s authority over federal congressional apportionment.
As
explained, the U.S. Constitution delegates that authority specifically to the General
Assembly—with only Congress itself being granted the power to override the General
Assembly’s actions. See U.S. Const. art. I, § 4, cl. 1. Given this evident construction,
constitutional doubt remains as to the nature and extent of other state actors’ ability to
transgress the legislature’s congressional-reapportionment power. See Moore, 600 U.S.
at 34 (declining to delineate a specific standard, but explaining that state courts “do not
have free rein” to revisit legislatures’ congressional reapportionments); Ariz. State Leg.,
576 U.S. at 825 (Roberts, C.J., dissenting) (summarizing the textual, structural, and
historical concerns of divesting state legislatures of their apportionment authority);
Carson, 978 F.3d at 1060 (“[A] legislature’s power in this area is such that it ‘cannot be
taken from them or modified’ even through ‘their state constitutions.’” (quoting
McPherson v. Blacker, 146 U.S. 1, 35 (1892))). Federal courts have already taken great
care to ensure that other state actors—absent “conclusively established” plain
direction—do not hamper the legislature’s Elections Clause authority in the name of
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state law. See Hildebrant, 241 U.S. at 568; see also Moore, 600 U.S. at 36 (emphasizing
how other state actors may not “arrogate to themselves the power vested in state
legislatures to regulate federal elections” without express authority); Carson, 978 F.3d
at 1060 (concluding that the legislature did not delegate authority to make major election
changes through “a general statute in the election code”). At the very least, the novelty
of Defendants’ efforts to place the General Assembly’s congressional redistricting on the
ballot raises alarm—especially because the U.S. Supreme Court has never passed on the
question in the context of an Elections Clause challenge. See Ariz. State Leg., 576 U.S.
at 825 (Roberts, C.J., dissenting) (discussing Hildebrant, 241 U.S. at 569).
57.
Given its novelty and lack of textual support, Defendants’ efforts to displace
the Federal Constitution’s vesting of redistricting authority in the General Assembly is
unlawful under the Elections Clause. The Missouri Constitution’s referendum provision
does not expressly say that a referendum can overturn the exercise of the General
Assembly’s federal redistricting decisions. To the contrary, the Missouri Constitution
specifically vests the General Assembly with the power to divide the State into
congressional districts. See Mo. Const. art. III, § 45 (stating General Assembly “shall”
perform this function). Given these provisions, Missouri has not yet made a deliberate
and clear choice to override the Elections Clause’s vesting the General Assembly with
congressional apportionment authority.
See Ariz. State Leg., 576 U.S. at 817
(emphasizing how the State had made the deliberate choice of reallocating that authority
to an independent commission).
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And Missouri should have a chance to make that knowing choice before this
unprecedented effort proceeds.
Subjecting Missouri’s congressional redistricting to
ballot referenda will invite chaos—driven by out-of-state special interests looking to gain
a partisan advantage in Congress. If Defendants succeed in using the referendum, every
apportionment decision going forward could now become subject to a referendum. In
effect, this could create apportionment paralysis—where the General Assembly is unable
to implement a congressional map because successive referendum efforts nullify them.
This threatens to wreak havoc on the General Assembly’s basic obligations to
reapportion congressional districts after each census. See Wesberry v. Sanders, 376 U.S.
1, 7–8 (1964).
59.
The problem runs even deeper than that. Under Defendants’ interpretation of
the Missouri Constitution, nothing would stop a voter from proposing the federal
congressional map in the first instance—thus entirely cutting the General Assembly out
of the redistricting process. The provision of the Missouri Constitution governing citizenproposed statutory initiatives is worded—in all material respects—identically to the
referendum provision. See Mo. Const. art. III, §§ 49–53. That provision just generally
refers to “laws”—without any specific reference to federal redistricting bills. See id. So,
under Defendants’ logic, voters—backed by out-of-state money—can just seize total
control of the federal redistricting process.
60.
The U.S. Constitution forecloses Defendants’ legal theory and actions. By
vesting authority in the state legislature, the Elections Clause made a “compromise” that
ensures a measure of deliberation, but in a representative body close to the people. Ariz.
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State Leg. at 837 (Roberts, C.J., dissenting).
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Nor does the Elections Clause leave
dissatisfied individuals—including Defendants—without recourse. They are free to take
their concerns to Congress itself, which can reset the reapportionment rules under the
Elections Clause. See Wise v. Circosta, 978 F.3d 93, 112 (4th Cir. 2020) (en banc)
(Wilkinson and Agee, JJ., dissenting) (emphasizing “the brilliance” of giving Congress
the authority to check state legislatures). They could also—through the citizen initiative
process—seek to amend the Missouri Constitution to give the people a role in reviewing
federal congressional maps through the referendum. See Mo. Const. art. III, §§ 49–51.
61.
Finally, no history in Missouri supports Defendants’ efforts. The Missouri
Supreme Court has never passed upon whether the referendum may be used to revisit
federal congressional redistricting. While a closely divided Missouri Supreme Court
upheld the use of referenda for apportionment of seats in the General Assembly, see State
ex rel. Gordon v. Becker, 49 S.W.2d 146, 149 (Mo. 1932), that case is inapt. To start,
federal and state legislative apportionment are governed by entirely separate provisions
in the Missouri Constitution. Mo. Const. art. III, §§ 3, 7, 10 (state); id. art. III, § 45
(congressional).
Additionally, Gordon never considered whether, per the Elections
Clause, the General Assembly retained sole authority to apportion congressional
districts.
Because the authority to set federal congressional districts is a power
delegated by the U.S. Constitution, federal congressional reapportionment implicates
uniquely federal interests not reflected in state-legislative reapportionment. See Moore,
600 U.S. at 34 (“As in other areas where the exercise of federal authority or the
vindication of federal rights implicates questions of state law, we have an obligation to
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ensure that state court interpretations of that law do not evade federal law.”); Carson,
978 F.3d at 1060 (emphasizing how setting federal elections occurs “‘by virtue of a direct
grant of authority’ under the United States Constitution”).
62.
If anything, Gordon casts further doubt on Defendants’ legal theory. Chief
Justice Atwood, in dissent, carefully analyzed Missouri constitutional history and
concluded that the Missouri Constitution was not originally understood to extend the
referendum even to state legislative apportionment. See Gordon, 49 S.W.2d at 152–57
(Atwood, C.J., dissenting) (contending that construction of prior Missouri constitutional
provisions did not support the practice). And if such doubt exists for state legislative
districting, it is hard to see how Defendants could satisfy the U.S. Constitution’s clearstatement rule applicable to federal congressional redistricting efforts.
63.
Defendants’ actions seeking a referendum vote on the General Assembly’s 2025
federal congressional redistricting bill violates the U.S. Constitution and the Missouri
Constitution. This Court should issue appropriate injunctive and declaratory relief.
CAUSES OF ACTION
Violation of the U.S. Constitution
Art. I, § 4, cl. 1
64.
Plaintiffs incorporate by reference all preceding paragraphs as if fully set forth
herein.
65.
An actual controversy exists within this Court’s jurisdiction that would be
resolved by a declaration of the rights and other legal relations of the parties in this
action—namely, that Defendants’ efforts to initiate a referendum overturning the
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General Assembly’s most recent congressional redistricting violates the Elections Clause
of the U.S. Constitution.
66.
The authority to prescribe the times, places, and manner of federal
congressional elections arises exclusively under the Elections Clause of the U.S.
Constitution.
67.
The Constitution delegates and conveys the authority to prescribe the times,
places, and manner of congressional elections only to “the Legislature” of “each State.”
U.S. Const. art. I, § 4, cl. 1. This delegation is a broad grant of power to the General
Assembly to prescribe the means by which congressional elections are held—including
the redistricting of federal congressional districts.
68.
Unless the Missouri Constitution plainly limits or divests the General
Assembly of its congressional-redistricting authority, the General Assembly retains its
power delegated by the Elections Clause.
69.
With no express authority bestowed on the referendum process to overturn
federal congressional apportionments, Defendants’ efforts to revisit the General
Assembly’s exercise of its authority under the Elections Clause are unlawful.
70.
For these reasons, the State and General Assembly are entitled to a judgment
declaring Defendants’ actions unlawful under the Elections Clause of the U.S.
Constitution. The Court should grant appropriate declaratory and injunctive relief.
Violation of the Missouri Constitution
Art. III, § 45
71.
Plaintiffs incorporate by reference all preceding paragraphs as if fully set forth
herein.
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As relevant, the Missouri Constitution provides that “the general assembly
shall by law divide the State into districts corresponding with the number of
[congressional] representatives to which it is entitled.” Mo. Const. art. III, § 45.
73.
No other provision of the Missouri Constitution strips the General Assembly
of its vested authority in redistricting the State’s congressional districts. See Mo. Const.
art. III, § 52(a).
74.
Because the Missouri Constitution does not specifically provide for referenda
to countermand federal congressional apportionments, the State and General Assembly
are entitled to a judgment declaring Defendants’ actions unlawful under the Missouri
Constitution and preliminarily and permanently enjoining them from continuing to
pursue any such referendum.
PRAYER FOR RELIEF
The Missouri General Assembly, Missouri Secretary of State Denny Hoskins,
and the State of Missouri pray that this Court:
1.
Declare, adjudge, and decree that the actions detailed herein are unlawful
under Article I, § 4, cl. 1, of the U.S. Constitution and Article III, § 45 of the Missouri
Constitution;
2.
Issue declaratory relief stating that Defendants’ proposed referendum is
unconstitutional;
3.
Issue temporary, preliminary, and permanent injunctive relief to prevent
Defendants from continuing to seek a referendum on the General Assembly’s
redistricting bill; and
4.
Award all other relief this Court deems equitable and just.
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Respectfully submitted,
CATHERINE L. HANAWAY
ATTORNEY GENERAL
s/ Louis J. Capozzi III
Louis J. Capozzi III, #77756(MO)
Solicitor General
William James Seidleck, #77794(MO)
Principal Deputy Solicitor General
Graham Miller, #77656(MO)
Deputy Solicitor General
OFFICE OF THE ATTORNEY GENERAL
Old Post Office Building
815 Olive Street, Suite 200
St. Louis, MO 63101
Phone: (573) 645-9662
Louis.Capozzi@ago.mo.gov
William.Seidleck@ago.mo.gov
Graham.Miller@ago.mo.gov
Counsel for Plaintiffs
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CERTIFICATE OF SERVICE
I hereby certify that true and correct copies of this Complaint shall be served
in accordance with Federal Rule of Civil Procedure 4.
s/ Louis J. Capozzi III
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Exhibit 2
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UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF MISSOURI
EASTERN DIVISION
MISSOURI GENERAL ASSEMBLY, et al.,
Plaintiffs,
v.
RICHARD VON GLAHN & PEOPLE NOT
POLITICIANS,
Defendants.
)
)
)
)
)
)
)
)
)
)
Case No. 4:25-CV-1535-ZMB
MEMORANDUM AND ORDER
This matter is before the Court on Plaintiffs’ Motion for a Preliminary Injunction, Doc. 2,
and Defendants’ Motion to Dismiss, Doc. 21. Plaintiffs—the State of Missouri, its General Assembly,
and its Secretary of State (“the State”)—brought this action for declaratory and injunctive relief to
prevent Defendants Richard Von Glahn and People Not Politics (“PNP”) from submitting a referendum
petition to reject a recent congressional-redistricting bill. PNP, in turn, has moved for dismissal on
multiple grounds, including ripeness and standing, and it also opposes relief on the merits.
After conducting a hearing and carefully considering the parties’ arguments, the Court holds
that this case is not ripe for adjudication. Critically, PNP concedes that Plaintiff Denny Hoskins
has the authority as Secretary of State to reject their petition as unconstitutional during postsubmission review and to defend that decision based on the very same constitutional arguments
the State advances in this case. See MO. REV. STAT. §§ 116.120, 116.200. Moreover, PNP agrees
that, absent a successful court challenge, this determination would obviate the need for signature
verification, publication, or a vote, and it also would prevent the displacement of the new map—the
only redressable harms the State identifies. Accordingly, given that the parties’ dispute is not ripe,
the Court must dismiss this action and deny the State’s motion for a preliminary injunction as moot.
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BACKGROUND
I.
Missouri’s Veto-Referendum Process
Under the Missouri Constitution, “[t]he people . . . reserve power to approve or reject by
referendum any act of the general assembly” with limited exceptions. MO. CONST. art. III, § 49. The
referendum process begins when a proponent submits a sample sheet to the Secretary of State, who
must “review the petition for sufficiency as to form” in conjunction with the Attorney General.
MO. REV. STAT. § 116.332. If the petition clears this initial review, the referendum organizers must
collect signatures from “five percent of the legal voters in each of two-thirds of the congressional
districts in the state . . . not more than ninety days after the final adjournment of the session of the
general assembly which passed the bill.” MO. CONST. art. III, § 52(a). The Secretary of State,
Attorney General, and State Auditor also must work together to prepare a fiscal note and summary
statement for the measure. MO. REV. STAT. §§ 116.175, 116.334. After the timely submission of a
final petition, the Secretary of State must “examine the petition to determine whether it complies
with the Constitution of Missouri and with [Chapter 116]” and verify whether there are enough
valid signatures to trigger a statewide vote. Id. § 116.120. If the Secretary finds that the petition
satisfies both requirements, see id. § 116.150, the challenged law is displaced and will only “take
effect when approved by a majority of the votes cast thereon,” MO. CONST. art. III, § 52(b).
II.
Relevant Facts
On August 29, 2025, Governor Mike Kehoe called a special session of Missouri’s General
Assembly, in part, to “enact legislation establishing updated congressional districts.” Doc. 1 ¶ 30.
The Missouri House of Representatives approved a redistricting bill on September 9, and the
Missouri Senate passed the same bill three days later. Id. ¶¶ 31–32. In response, PNP immediately
initiated a referendum campaign to overturn the newly enacted map. Id. ¶¶ 39–40. In fact, PNP
submitted its initial petition before the Governor signed the bill into law. Id. ¶¶ 33, 38.
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Secretary Hoskins and Attorney General Catherine Hanaway rejected PNP’s first petition
because it preceded the Governor’s signature (itself the subject of litigation). Docs. 3-4, 3-5. But they
approved a subsequent petition, at least as to form. See Doc. 3-7. The State Auditor also prepared a
fiscal note, which indicates that ballot measures over the last decade have cost, on average, more
than $500,000. Doc. 25-1; see also Doc. 3-1 ¶ 19 (estimating this referendum may cost $10 million
due to publication costs). Most recently, Secretary Hoskins and Attorney General Hanaway approved
a summary statement of the measure (also the subject of litigation). See Doc. 29 at 14; MO. ATT’Y
GEN., OP. LETTER NO. 329-2025, at 1. And beyond these official actions, interested parties have
filed a series of lawsuits in state court as the referendum process progressed. Doc. 29 at 12–13. 1
Looking forward, if PNP submits its final petition as anticipated, Secretary Hoskins must
review its legality, may have to verify signatures, 2 and will issue a certificate of sufficiency or
insufficiency. Doc. 1 ¶ 46. If the petition is sufficient, the State must hold a public hearing and
take comments from the public, prepare the ballot initiative, and publicize the referendum. Id. ¶ 47;
Doc. 3 at 11. Most important to the State, the new map will be frozen until after the referendum,
which could significantly disrupt the 2026 elections. Doc. 1 ¶ 48; Doc. 3 at 11.
Indeed, there are at least six cases that could impact the merits of the instant action: Luther v. Hoskins, No. 25ACCC06964 (Mo. 19th Cir. Ct. Sept. 12, 2025) (challenging the General Assembly’s ability to conduct mid-decade
redistricting); People Not Politicians v. Hoskins, No. 25AC-CC07128 (Mo. 19th Cir. Ct. Sept. 18, 2025) (challenging
Secretary Hoskins’s rejection of the initial sample sheet); Wise v. Missouri, No. 2516-CV29597 (Mo. 16th Cir. Ct.
Sept. 12, 2025) (challenging the new congressional map under the Missouri Constitution); NAACP v. Kehoe, No.
25AC-CC06724 (Mo. 19th Cir. Ct. Sept. 3, 2025) (challenging the Governor’s ability to convene a special session for
the purpose of mid-decade redistricting); Healey v. Missouri, No. 2516-CV31273 (Mo. 16th Cir. Ct.. Sept. 28, 2025)
(challenging mid-decade redistricting generally and the new map’s compactness); People Not Politicians, et al. v.
Hoskins, No. 25AC-CC08724 (Mo. 19th Cir. Nov. 20, 2025) (challenging the ballot summary language).
1
The plan language of MO. REV. STAT. §116.120 implies but does not specify this sequence of review. However, the
Missouri Court of Appeals has construed silence in this provision as a grant of discretion to the Secretary of State, and
there is no apparent reason why he would incur the significant cost of signature verification given his stated belief that
the petition is constitutionally deficient. See Sweeney v. Ashcroft, 652 S.W.3d 711, 733 (Mo. Ct. App. 2022) (“The
manner in which the secretary of state fulfills this mandatory duty is not clearly, unambiguously, or unequivocally
limited by any statutory provision.”). Most importantly, the parties agree that Secretary Hoskins can take this approach
and have indicated their expectation that he will do so. See, e.g., Doc. 1 ¶ 46; Doc. 22 at 34–35; Doc. 38 at 33–35, 43–44.
2
3
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Procedural History
On October 15, 2025, the State filed its complaint, seeking two forms of relief: (1) a
declaratory judgment that PNP’s referendum is unlawful under both the United States and Missouri
Constitutions, and (2) an injunction to prevent PNP from continuing its referendum. Doc. 1 at 22.
The State simultaneously filed a Motion for a Preliminary Injunction. Doc. 2. While initially seeking
expedited review, Doc. 3 at 14, the State withdrew that request after PNP agreed to not submit a
final petition before December 9, Doc. 38 (“Tr.”) at 59. PNP timely filed its merits opposition and
a motion to dismiss, and both motions were fully briefed on November 20. Docs. 21, 29, 32.
The Court held a hearing on the dueling motions on November 25. Doc. 35. At the hearing,
the parties agreed that Secretary Hoskins must independently review the constitutionality of the
referendum petition and that he could defend a decertification decision based on the constitutional
claims at issue here. Tr. at 34–35, 43–44. They also agreed that, if the Secretary rejected the
petition, the new map would go into effect unless and until a court invalidated the decertification.
Id. at 36, 48, 49–50, 52. Finally, the State confirmed it is not seeking recovery of any presubmission damages, only prospective relief as to PNP’s submission of a final petition. Id. at 19, 35.
LEGAL STANDARD
Under Federal Rule of Civil Procedure 12(b)(1), a defendant may move to dismiss a case for
lack of standing. Disability Support All. v. Heartwood Enters., 885 F.3d 543, 547 (8th Cir. 2018)
(“Standing is a jurisdictional issue.”). “No principle is more fundamental to the judiciary’s proper
role in our system of government than the constitutional limitation of federal-court jurisdiction to
actual cases or controversies.” McNaught v. Nolen, 76 F.4th 764, 768 (8th Cir. 2023) (citation omitted).
As the party invoking jurisdiction, each plaintiff has the burden of establishing standing by
showing that they “have (1) suffered an injury in fact, (2) that is fairly traceable to the challenged
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conduct of the defendant, and (3) that is likely to be redressed by a favorable judicial decision.”
Id. at 768–70 (quoting Spokeo, Inc. v. Robins, 578 U.S. 330, 338 (2016)). Further, a plaintiff must
have standing as to each asserted harm, which are evaluated independently. See BCR Safeguard
Holding v. Morgan Stanley, 614 F. App’x 690, 698 (5th Cir. 2015) (citation omitted); see also
Frost v. Sioux City, 920 F.3d 1158, 1161 (8th Cir. 2019) (taking this approach); DiPierro v. Fla.
Health Scis. Ctr., 737 F. Supp. 3d 1314, 1322 (M.D. Fla. 2024) (“[A] plaintiff’s proffered harms
must be analyzed on a claim-by-claim, harm-by-harm basis.”).
Closely related to standing are the doctrines of ripeness and mootness, which address
similar considerations at different time frames. A claim is not ripe when “it rests upon contingent
future events that may not occur as anticipated, or indeed may not occur at all.” KCCP Trust v. City
of N. Kansas City, 432 F.3d 897, 899 (8th Cir. 2005) (quotation omitted); Bergstrom v. Bergstrom,
623 F.2d 517, 519 (8th Cir. 1980) (explaining that ripeness doctrine counsels against “passing upon
constitutional questions in advance of the strictest necessity for deciding them”). The Eighth Circuit
applies a two-pronged test for ripeness, with the plaintiff required to “show both the fitness of the
issues for judicial decision and the hardship to the parties of withholding court consideration.”
Iowa League of Cities v. EPA, 711 F.3d 844, 867 (8th Cir. 2013) (quotation omitted). The related
mootness doctrine ensures that the “personal interest that must exist at the commencement of the
litigation . . . continue[s] throughout its existence.” McNaught, 76 F.4th at 769 (quotation omitted).
DISCUSSION
The parties have presented a host of issues, but the Court cannot address them all because it
lacks jurisdiction over this case. Given Secretary Hoskins’s unique self-help remedy, the State’s only
cognizable injuries are not ripe. Alternatively, the Court must abstain under the Pullman doctrine as
relevant questions of state constitutional law will be decided by the Secretary or in state court.
5
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Standing, Ripeness, and Mootness
After excluding the State’s non-redressable injuries, this lawsuit is not ripe for adjudication.
The State’s asserted harms—as articulated in the Complaint, through its briefing, and at the
hearing—fall into three buckets, which the Court will consider in turn. No injury justifies standing.
The State first highlights the harms that predated this lawsuit. These injuries include the
cost of processing the referendum petition and litigating state-court cases. Doc. 1 ¶¶ 43–45, 50;
Doc. 3 at 10; Tr. at 25, 32–33. To its credit, however, the State acknowledges it is not relying on
these previously expended resources to establish standing given that it seeks only prospective
relief. Tr. at 35; see Frost, 920 F.3d at 1161–62 (refusing to consider past harms for redressability
purposes, as “[a]n injunction is inherently prospective and cannot redress past injuries”).
Second, the State points to the ongoing injuries it has suffered during this case through
PNP’s anticipated submission of a final petition tomorrow. This category is similar to the State’s
past harms and includes referendum-processing obligations, unspecified investigations, and
litigation expenses. 3 Doc. 1 ¶¶ 43–45; Doc. 25-1; Doc. 29 at 12–15; Tr. 32–33. These injuries are
likewise insufficient to establish standing. Even if they were redressable at the outset of the case,
the State abandoned its ability to prevent these harms when it agreed to forego emergency relief
until now. See Tr. at 59. Thus, whether viewed through the lens of waiver or mootness, the Court
cannot redress these injuries. Tr. at 35 (acknowledging that, “as time passes, [ongoing harms]
become no longer redressable”); see McFarlin v. Newport Special Sch. Dist., 980 F.2d 1208, 1210
(8th Cir. 1992) (“Through the passage of time and the occurrence of irrevocable events, disputes
may disappear so that federal courts no longer can grant effective relief.”).
The State has not identified a single case holding that parallel-litigation expenses can confer standing, nor has the
Court found any. But even assuming such costs could amount to a cognizable injury, the State’s invocation of its statecourt litigation with PNP plainly falls short. See Doc. 1 ¶¶ 45, 50; Doc. 3 at 10–11; Doc. 29 at 12–13. As an initial
matter, it is far from clear that the Court could enjoin PNP from pursuing these cases or otherwise halt the litigation,
see Doc. 22 at 11 n.5, underscoring why this harm is nothing like the State’s analogy to agency “compliance costs,”
see Doc. 29 at 12–13. More importantly, the State never requested this remedy. See Doc. 1 at 22; Doc. 2. Thus, even
if the Court granted both declaratory and injunctive relief, PNP would be free to litigate these cases and likely would
do so while it pursued an appeal in the Eighth Circuit. In sum, the State’s litigation-expense injury lacks redressability.
3
6
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Third, and most importantly, are the future injuries the State anticipates. Assuming PNP
submits a final petition, Secretary Hoskins will need to review it for constitutional validity and
potentially verify the accompanying signatures; and if the referendum advances, the State will
incur a series of costs, including at least a temporary displacement of the recently enacted map. See
Doc. 1 ¶¶ 46–48; Doc. 3 at 11; Doc. 29 at 14, 18. Fortunately for the State, Secretary Hoskins has
a tool at his disposal that almost no other litigant could boast—the power to declare the petition
unconstitutional himself. And at this point, decertification would forestall any remaining
cognizable harms. 4 The State’s only response for why this unique self-help remedy does not
amount to a ripeness defect is that drafting a certificate of insufficiency will “require careful
analysis and collaboration between the Secretary and Attorney General.” See Doc. 29 at 15. But it
is hard to imagine that completing this constitutional assessment will impose any measurable
burden given that the State has completed an exhaustive analysis in briefing this case. In other
At the hearing, the State expressed concern that PNP would backslide on its repeated representations to this Court
that the Secretary of State will have the opportunity to review the final petition for constitutionality before conducting
signature verification, that he could at least defend a finding of unconstitutionality based on the same claims the State
advances in this case, and that the new map would go into effect barring a successful challenge to decertification. See
Tr. at 51–52. But see, e.g., Doc. 22 at 1, 8, 11-12, 13–14, 34–35, 38; Doc. 32 at 4, 6; Tr. at 43–44, 48–50. While the
State cannot be faulted for failing to anticipate these concessions at the outset of the case, the Court has expressly
found that PNP affirmatively waived these points, see Tr. at 52, precluding any argument to the contrary in future
litigation (to say nothing of the ethical ramifications of counsel breaching their duty of candor to this tribunal).
4
In any event, the Court’s review of Missouri law indicates that a contrary position would plainly fail. There is no doubt
that the Secretary of State has both the authority and duty to assess the constitutionality of the final petition. See MO.
REV. SAT. § 116.120 (requiring that, upon submission, the Secretary “shall examine the petition to determine whether
it complies with the Constitution of Missouri and with this chapter”); Missourians to Protect the Initiative Process v.
Blunt, 799 S.W.2d 824, 828 (Mo. banc 1990) (rejecting a claim that constitutional review was limited to signature
provisions because “the language used [in section 116.120] mandates a more extensive examination”). Given the
State’s position that PNP’s referendum violates the Missouri Constitution itself, see Doc. 1 ¶¶ 71–74, that finding
alone is sufficient for decertification. Moreover, the Secretary of State has an independent obligation flowing from his
oath of office “to support the Constitution of the United States and of [Missouri].” MO. REV. STAT. § 28.020. And if
the Secretary perceived any conflict between the Missouri and United States Constitution, he might argue that the
Supremacy Clause prevents him from taking an action permitted by the latter but forbidden by the former.
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words, there would be no “hardship to the parties [from] withholding court consideration.” 5 See
KCCP Trust, 432 F.3d at 899 (quotation omitted); see also Neb. Pub. Power Dist. v. MidAmerican
Energy Co., 234 F.3d 1032, 1038 (8th Cir. 2000) (requiring a showing of “significant harm”).
One final point warrants a brief mention. At the hearing, the State cited Calzone v. Ashcroft
to suggest that Missouri courts may conclude that the Secretary of State lacks authority to conduct
“a full constitutional review” before a referendum vote. Tr. at 33–34. But in Calzone, the Secretary
already certified the petition, and the Missouri Court of Appeals held only that “Missouri courts
recognize and follow a general rule against pre-election judicial review concerning the substantive
legality of ballot measures.” 559 S.W.3d 32, 35 (Mo. Ct. App. 2018) (emphasis added). Thus, that
case says nothing about the Secretary’s authority to decertify a petition on constitutional grounds.
Moreover, the ripeness concerns underpinning Calzone would not be present in that scenario
because there would be no vote to await absent court intervention. And even if state ripeness
doctrine were relevant, a state court likely could hear the case because the State’s claims relate to
“constitutional requirements and limits of power” as to whether the referendum can even occur, not
the substance of the underlying measure (i.e., the validity of the map). See Blunt, 799 S.W.2d at 827–
29 (collecting cases where “courts have conducted a pre-election review to determine if conditions
precedent to placing a proposal on the ballot have been met”).
As detailed above, the State’s past injuries are no longer redressable because it seeks only
prospective relief. And given Secretary Hoskins’s ability to vindicate the State’s interests, the only
cognizable injuries are not ripe for adjudication. Accordingly, the Court must dismiss this case.
The Secretary’s access to a self-help tool creates another stranding problem, in that post-submission review also
breaks the chain of causation between PNP’s actions and his alleged harms. See Johnson v. U.S. Off. of Pers. Mgmt.,
783 F.3d 655, 667-68 (7th Cir. 2015) (“[P]laintiffs cannot allege an injury from one of multiple options where they
can choose another which causes them no injury.”) (quotation omitted); cf. Berkadia Real Est. Advisors v. Wadlund,
No. CV-22-00049-TUC-JCH, 2022 WL 18495279, at *17 (D. Ariz. Mar. 3, 2022) (denying a preliminary injunction
because the plaintiff could exercise self-help). The same is true for the General Assembly and the State of Missouri,
whose injuries depends on the Secretary’s review, likewise breaking the chain of causation for their claims. See E.L.
ex rel. White v. Voluntary Interdistrict Choice Corp., 864 F.3d 932, 936 (8th Cir. 2017) (no causation for standing
purposes when the injury “is the result of actions by some third party, not the defendant”) (quotation omitted).
5
8
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II.
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Pullman Abstention
Alternatively, even if the case were justiciable, Pullman abstention would be warranted.
Like other abstention doctrines, Pullman applies when federal courts exercise discretion to depart
from their general obligation to exercise jurisdiction and “abstain from deciding an issue in order
to preserve traditional principles of equity, comity, and federalism.” Beavers v. Ark. State Bd. of
Dental Exam’rs, 151 F.3d 838, 840 (8th Cir. 1998) (quotations omitted). The Pullman abstention
doctrine requires the Court to consider five factors:
(1) the effect abstention would have on the rights to be protected by considering the
nature of both the right and necessary remedy; (2) available state remedies; (3)
whether the challenged state law is unclear; (4) whether the challenged state law is
fairly susceptible to an interpretation that would avoid any federal constitutional
question; and (5) whether abstention will avoid unnecessary federal interference in
state operations.
Id. at 841. In particular, courts should avoid “needless friction between federal pronouncements
and state policies,” especially in cases involving “a matter of great state concern.” See Reetz v.
Bozaich, 397 U.S. 82, 87 (1970) (abstaining from issuing declaration that state fishing laws
violated the Fourteenth Amendment and the Alaska Constitution) (quotation omitted); see also,
e.g., Harris Cnty. Comm’rs Ct. v. Moore, 420 U.S. 77, 85 (1975) (noting that abstention is
appropriate where “the nub of the whole controversy may be the state constitution”).
Applying the Eighth Circuit’s Pullman test, the Court concludes that abstention would be
warranted. The first factor—“the effect abstention would have on the rights to be protected”—
weighs strongly in favor of the PNP, as the State may protect its own interests through
decertification. See Beavers, 151 F.3d at 841. The last three factors—whether the state law is
unclear, whether that law is susceptible to interpretation avoiding the federal constitutional
question, and whether the abstention avoids federal interference in state operations—also
decidedly weigh in favor of PNP. Here, the State’s case rests on the premise that Missouri’s
9
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Constitution does not provide a “clear statement” permitting a veto referendum on redistricting
bills and, thus, that the General Assembly retains exclusive authority to redistrict in light of the
Elections Clause. Doc. 1 ¶¶ 4–7, 50–63. At a minimum, the State has conceded that the law is
unclear. See Doc. 1 ¶ 6. And as explained above, a decision that the Missouri Constitution does
not permit a redistricting referendum would moot the State’s federal constitutional claims, while
a decision that it does clearly permit them would significantly narrow the issues. Further,
abstaining here would avoid federal interference in a referendum process created entirely by the
Missouri Constitution and state law.
With abstention all but decided, the State contends that the second factor—“available state
remedies”—torpedoes the whole analysis because it likely will be unable to raise its Elections
Clause claim before the future harms occur. Tr. at 6–7, 21. But Secretary Hoskins has a self-help
remedy under state law in the form of decertification for unconstitutionality. See Fender v.
Washington Cnty., No. 14-CV-0142, 2014 WL 1491138, at *3 (W.D. Pa. Apr. 15, 2014)
(recognizing that “questions must be resolved at the state level—both administratively and
judicially—before this Court may properly analyze the underlying federal constitutional claim.”).
The State also cited to Pennzoil Co. v. Texaco at the hearing, arguing that it counseled abstention
where no pending state court action existed, unless the court’s opinion would almost certainly be
advisory. See Tr. at 25 (citing 481 U.S. 1, 11 (1987)). But that case involved Younger, rather than
Pullman, abstention. Id. at 10. While “various types of abstention are not rigid pigeonholes,”
different principles govern the application of these doctrines, and accordingly, the case is
inapposite. Id. at 11 n.9. More importantly, as PNP notes, there was no pending state court case in
Pullman itself, so this factor is by no means required. See Doc. 33 at 15 (citing R.R. Comm’n v.
Pullman Co., 312 U.S. 496, 501–02 (1941)).
10
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The last aspect of abstention the Court must consider is whether to grant dismissal or hold
the case in abeyance pending a state determination. While courts are required to stay an action at
law “pending [the] completion of state proceedings,” the Eighth Circuit has recognized that
dismissal or remand may be appropriate for equitable actions “based on abstention principles.”
Warmus v. Melahn, 110 F.3d 566, 567 (8th Cir. 1997). In addition to the nature of this action and
important state interests at play, the Court notes that this case will almost certainly be moot by the
time a probably state court lawsuit is filed because decertification would leave this Court with no
meaningful relief to grant. Accordingly, the Court would dismiss on abstention grounds.
CONCLUSION
Accordingly, the Court GRANTS Defendants’ [21] Motion to Dismiss and DENIES as
moot the State’s [2] Motion for a Preliminary Injunction. The Court will issue a separate Order of
Dismissal to accompany this order.
So ordered this 8th day of December 2025.
ZACHARY M. BLUESTONE
UNITED STATES DISTRICT JUDGE
11
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103a
26AC-CC00440
Exhibit 4
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
SC101805 Appeal Document Number 6 Page 1
SECOND EXTRAORDINARY SESSION OF THE
FIRST REGULAR SESSION
[TRULY AGREED TO AND FINALLY PASSED]
HOUSE BILL NO. 1
103RD GENERAL ASSEMBLY
3344H.01T
2025
AN ACT
To repeal sections 128.345, 128.346, and 128.348, RSMo, and to enact in lieu thereof twelve
new sections relating to the composition of congressional districts.
Be it enacted by the General Assembly of the state of Missouri, as follows:
2
3
4
2
3
4
5
6
2
3
4
5
6
7
8
9
Section A. Sections 128.345, 128.346, and 128.348, RSMo, are repealed and twelve
new sections enacted in lieu thereof, to be known as sections 128.345, 128.346, 128.348,
128.471, 128.472, 128.473, 128.474, 128.475, 128.476, 128.477, 128.478, and 128.479, to
read as follows:
128.345. 1. All references in sections 128.451 to 128.458 to counties, voting districts
(VTD), and tract-blocks (Block) mean those counties, voting districts (VTD), and tract-blocks
(Block) as reported to the state by the United States Bureau of the Census for the 2010 census.
2. All references in sections 128.461 to [128.468] 128.478 to counties, voting districts
(VTD), and tract-blocks (Block) mean those counties, voting districts (VTD), and tract-blocks
(Block) as reported to the state by the United States Bureau of the Census for the 2020 census.
128.346. 1. The districts established by the provisions of sections 128.400 to 128.440
for the election of representatives to the Congress of the United States shall be effective
beginning with election to the 108th Congress and through the election of the 112th Congress.
2. The districts established by sections 128.451 to 128.458 for the election of
representatives to the Congress of the United States shall be effective beginning with the
election to the 113th Congress and through the election of the 117th Congress.
3. The districts established by sections 128.461 to 128.468 for the election of
representatives to the Congress of the United States shall be effective beginning with the
election to the 118th Congress and through the election of the 119th Congress.
EXPLANATION — Matter enclosed in bold-faced brackets [thus] in the above bill is not enacted and is
intended to be omitted from the law. Matter in bold-face type in the above bill is proposed language.
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
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SC101805 Appeal Document Number 6 Page 2
HB 1
2
10
4. The districts established by sections 128.471 to 128.478 for the election of
11 representatives to the Congress of the United States shall be effective beginning with the
12 election of the 120th Congress.
128.348. 1. Effective with the election for the 113th Congress and through the
2 election of the 117th Congress, the state of Missouri shall consist of eight congressional
3 districts.
4
2. Effective with the election of the 118th Congress, the state of Missouri shall consist
5 of eight congressional districts.
6
3. Effective with the election of the 120th Congress, the state of Missouri shall
7 consist of eight congressional districts.
8
4. The legal voters of each district shall elect one member of Congress of the United
9 States.
128.471. The first congressional district shall be composed of the following:
2
County: St. Louis City MO
3
County: St. Louis MO
4
VTD: AP001
5
VTD: AP002
6
VTD: AP003
7
VTD: AP004
8
VTD: AP005
9
VTD: AP006
10
VTD: AP007
11
VTD: AP008
12
VTD: AP009
13
VTD: AP010
14
VTD: AP011
15
VTD: AP012
16
VTD: AP013
17
VTD: AP014
18
VTD: AP015
19
VTD: AP016
20
VTD: AP017
21
VTD: AP018
22
VTD: AP019
23
VTD: AP020
24
VTD: AP021
25
VTD: AP022
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
105a
SC101805 Appeal Document Number 6 Page 3
HB 1
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
59
60
61
62
3
VTD: AP023
VTD: AP024
VTD: AP025
VTD: AP026
VTD: AP027
VTD: AP028
VTD: AP029
VTD: AP030
VTD: AP031
VTD: AP033
VTD: AP034
VTD: AP035
VTD: AP036
VTD: AP037
VTD: AP038
VTD: AP039
VTD: AP040
VTD: AP042
VTD: AP043
VTD: AP044
VTD: AP045
VTD: AP046
VTD: AP047
VTD: AP048
VTD: AP049
VTD: AP050
VTD: AP051
VTD: AP200
VTD: AP203
VTD: AP206
VTD: AP207
VTD: AP208
VTD: AP211
VTD: AP214
VTD: AP215
VTD: AP216
VTD: AP217
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
106a
SC101805 Appeal Document Number 6 Page 4
HB 1
63
64
65
66
67
68
69
70
71
72
73
74
75
76
77
78
79
80
81
82
83
84
85
86
87
88
89
90
91
92
93
94
95
96
97
98
99
4
VTD: AP218
VTD: AP225
VTD: AP230
VTD: AP232
VTD: AP233
VTD: AP237
VTD: CC012
VTD: CC013
VTD: CC022
VTD: CC043
VTD: CC048
Block: 291892155004011
VTD CC048 Subtotal
VTD: CC051
VTD: CC057
VTD: CC203
Block: 291892156001019
VTD CC203 Subtotal
VTD: CC205
VTD: CLA001
VTD: CLA002
VTD: CLA003
VTD: CLA004
Block: 291892165004005
Block: 291892165004006
Block: 291892165004007
Block: 291892165004008
Block: 291892165004009
Block: 291892165004010
Block: 291892165004011
Block: 291892165004012
Block: 291892165004013
Block: 291892165004014
Block: 291892165004015
Block: 291892165004016
Block: 291892165004017
Block: 291892165004018
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
107a
SC101805 Appeal Document Number 6 Page 5
HB 1
100
101
102
103
104
105
106
107
108
109
110
111
112
113
114
115
116
117
118
119
120
121
122
123
124
125
126
127
128
129
130
131
132
133
134
135
136
5
Block: 291892165004019
Block: 291892165004020
Block: 291892165004022
Block: 291892165004023
Block: 291892165004024
Block: 291892165004025
Block: 291892165004026
VTD CLA004 Subtotal
VTD: CLA005
VTD: CLA008
VTD: CLA009
VTD: CLA010
VTD: CLA011
VTD: CLA013
Block: 291892165004021
VTD CLA013 Subtotal
VTD: CLA017
VTD: CLA019
VTD: CLA020
VTD: CLA021
VTD: CLA022
VTD: CLA023
VTD: CLA027
VTD: CLA029
VTD: CLA030
VTD: CLA031
VTD: CLA032
VTD: CLA035
VTD: CLA038
VTD: CLA039
VTD: CLA041
VTD: CLA043
VTD: CLA044
VTD: CLA046
VTD: CLA050
VTD: CLA051
VTD: CLA052
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
108a
SC101805 Appeal Document Number 6 Page 6
HB 1
137
138
139
140
141
142
143
144
145
146
147
148
149
150
151
152
153
154
155
156
157
158
159
160
161
162
163
164
165
166
167
168
169
170
171
172
173
6
VTD: CLA200
VTD: CLA206
VTD: FER001
VTD: FER002
VTD: FER003
VTD: FER004
VTD: FER005
VTD: FER006
VTD: FER007
VTD: FER008
VTD: FER009
VTD: FER010
VTD: FER011
VTD: FER012
VTD: FER013
VTD: FER014
VTD: FER015
VTD: FER016
VTD: FER017
VTD: FER018
VTD: FER019
VTD: FER020
VTD: FER021
VTD: FER022
VTD: FER023
VTD: FER024
VTD: FER025
VTD: FER026
VTD: FER027
VTD: FER028
VTD: FER029
VTD: FER030
VTD: FER031
VTD: FER032
VTD: FER033
VTD: FER034
VTD: FER035
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
109a
SC101805 Appeal Document Number 6 Page 7
HB 1
174
175
176
177
178
179
180
181
182
183
184
185
186
187
188
189
190
191
192
193
194
195
196
197
198
199
200
201
202
203
204
205
206
207
208
209
210
7
VTD: FER036
VTD: FER037
VTD: FER038
VTD: FER039
VTD: FER040
VTD: FER041
VTD: FER042
VTD: FER043
VTD: FER044
VTD: FER045
VTD: FER046
VTD: FER206
VTD: FER207
VTD: FER208
VTD: FLO001
VTD: FLO002
VTD: FLO003
VTD: FLO004
VTD: FLO005
VTD: FLO006
VTD: FLO007
VTD: FLO008
VTD: FLO009
VTD: FLO010
VTD: FLO011
VTD: FLO012
VTD: FLO013
VTD: FLO014
VTD: FLO015
VTD: FLO016
VTD: FLO017
VTD: FLO018
VTD: FLO019
VTD: FLO020
VTD: FLO021
VTD: FLO022
VTD: FLO023
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
110a
SC101805 Appeal Document Number 6 Page 8
HB 1
211
212
213
214
215
216
217
218
219
220
221
222
223
224
225
226
227
228
229
230
231
232
233
234
235
236
237
238
239
240
241
242
243
244
245
246
247
8
VTD: FLO024
VTD: FLO025
VTD: FLO026
VTD: FLO027
VTD: FLO028
VTD: FLO029
VTD: FLO030
VTD: FLO031
VTD: FLO200
VTD: FLO201
VTD: FLO205
VTD: FLO207
VTD: GRA007
Block: 291892198011012
Block: 291892198011013
Block: 291892198011014
Block: 291892198011020
Block: 291892198012013
Block: 291892198012015
Block: 291892198012016
VTD GRA007 Subtotal
VTD: GRA015
Block: 291892197003015
Block: 291892197005003
Block: 291892197005004
Block: 291892197005005
Block: 291892197005006
Block: 291892197005007
Block: 291892197005008
Block: 291892197005010
Block: 291892197005011
Block: 291892197005012
Block: 291892197005013
VTD GRA015 Subtotal
VTD: GRA016
VTD: GRA018
VTD: GRA019
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
111a
SC101805 Appeal Document Number 6 Page 9
HB 1
248
249
250
251
252
253
254
255
256
257
258
259
260
261
262
263
264
265
266
267
268
269
270
271
272
273
274
275
276
277
278
279
280
281
282
283
284
9
Block: 291892197001024
Block: 291892197003006
Block: 291892197003007
Block: 291892197003008
Block: 291892197003009
Block: 291892197003010
Block: 291892197003011
Block: 291892197003012
Block: 291892197003013
Block: 291892197003014
Block: 291892197005002
Block: 291892197005014
Block: 291892197005015
Block: 291892198012001
Block: 291892198012002
Block: 291892198013017
VTD GRA019 Subtotal
VTD: GRA021
VTD: GRA022
VTD: GRA025
VTD: GRA033
Block: 291892199001000
Block: 291892199001001
Block: 291892199001002
Block: 291892199001003
Block: 291892199001004
Block: 291892199001005
Block: 291892199001006
Block: 291892199001008
Block: 291892199001009
VTD GRA033 Subtotal
VTD: GRA035
VTD: GRA039
VTD: GRA045
Block: 291892208011021
Block: 291892208011023
VTD GRA045 Subtotal
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
112a
SC101805 Appeal Document Number 6 Page 10
HB 1
285
286
287
288
289
290
291
292
293
294
295
296
297
298
299
300
301
302
303
304
305
306
307
308
309
310
311
312
313
314
315
316
317
318
319
320
321
10
VTD: GRA202
Block: 291892208011018
VTD GRA202 Subtotal
VTD: HAD001
VTD: HAD002
VTD: HAD003
VTD: HAD004
VTD: HAD005
VTD: HAD006
VTD: HAD007
VTD: HAD008
VTD: HAD009
VTD: HAD010
VTD: HAD011
VTD: HAD012
VTD: HAD013
VTD: HAD014
VTD: HAD015
VTD: HAD016
VTD: HAD017
VTD: HAD018
VTD: HAD019
VTD: HAD020
VTD: HAD021
VTD: HAD022
VTD: HAD023
VTD: HAD024
VTD: HAD025
VTD: HAD026
VTD: HAD027
VTD: HAD028
VTD: HAD029
VTD: HAD030
VTD: HAD031
VTD: HAD032
VTD: HAD033
VTD: HAD034
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
113a
SC101805 Appeal Document Number 6 Page 11
HB 1
322
323
324
325
326
327
328
329
330
331
332
333
334
335
336
337
338
339
340
341
342
343
344
345
346
347
348
349
350
351
352
353
354
355
356
357
358
11
VTD: HAD035
VTD: HAD200
VTD: JEF005
VTD: JEF006
VTD: JEF007
VTD: JEF008
VTD: JEF009
VTD: JEF010
Block: 291892194001026
Block: 291892194003018
Block: 291892194004000
Block: 291892194004001
Block: 291892194004002
Block: 291892194004003
Block: 291892194004004
Block: 291892194004005
Block: 291892194004006
Block: 291892194004007
Block: 291892194004008
Block: 291892194004010
Block: 291892194004011
Block: 291892194004012
Block: 291892194004013
Block: 291892194004014
Block: 291892194004015
Block: 291892194005001
Block: 291892194005002
Block: 291892194005005
Block: 291892194005006
Block: 291892194005007
Block: 291892194005015
Block: 291892194005016
Block: 291892194005017
Block: 291892194005018
Block: 291892194005019
Block: 291892194005020
Block: 291892194005021
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
114a
SC101805 Appeal Document Number 6 Page 12
HB 1
359
360
361
362
363
364
365
366
367
368
369
370
371
372
373
374
375
376
377
378
379
380
381
382
383
384
385
386
387
388
389
390
391
392
393
394
395
12
Block: 291892194005022
VTD JEF010 Subtotal
VTD: JEF011
VTD: JEF012
VTD: JEF013
VTD: JEF014
VTD: JEF015
VTD: JEF016
VTD: JEF017
VTD: JEF018
VTD: JEF019
VTD: JEF020
VTD: JEF021
VTD: JEF022
VTD: JEF023
VTD: JEF024
VTD: JEF025
VTD: JEF026
VTD: JEF027
VTD: JEF028
VTD: JEF029
VTD: JEF030
VTD: JEF031
VTD: JEF202
VTD: LC001
VTD: LC002
VTD: LC003
VTD: LC004
VTD: LC005
VTD: LC006
VTD: LC007
VTD: LC008
VTD: LC009
VTD: LC010
VTD: LC011
VTD: LC012
VTD: LC013
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
115a
SC101805 Appeal Document Number 6 Page 13
HB 1
396
397
398
399
400
401
402
403
404
405
406
407
408
409
410
411
412
413
414
415
416
417
418
419
420
421
422
423
424
425
426
427
428
429
430
431
432
13
VTD: LC014
VTD: LC015
VTD: LC016
VTD: LC017
VTD: LC018
VTD: LC019
VTD: LC020
VTD: LC021
VTD: LC022
VTD: LC023
VTD: LC024
VTD: LC025
VTD: LC026
VTD: LC027
VTD: LC028
VTD: LC029
VTD: LC030
VTD: LC031
VTD: LC032
VTD: LC033
VTD: LC200
VTD: LC203
VTD: LC204
VTD: LC209
VTD: MID001
VTD: MID002
VTD: MID003
VTD: MID004
VTD: MID005
VTD: MID006
VTD: MID007
VTD: MID008
VTD: MID009
VTD: MID010
VTD: MID011
VTD: MID012
VTD: MID013
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
116a
SC101805 Appeal Document Number 6 Page 14
HB 1
433
434
435
436
437
438
439
440
441
442
443
444
445
446
447
448
449
450
451
452
453
454
455
456
457
458
459
460
461
462
463
464
465
466
467
468
469
14
VTD: MID014
VTD: MID015
VTD: MID016
VTD: MID017
VTD: MID018
VTD: MID019
VTD: MID020
VTD: MID021
VTD: MID022
VTD: MID023
VTD: MID024
VTD: MID025
VTD: MID026
VTD: MID027
VTD: MID028
VTD: MID029
VTD: MID030
VTD: MID031
VTD: MID032
VTD: MID033
VTD: MID034
VTD: MID035
VTD: MID036
VTD: MID037
VTD: MID038
VTD: MID039
VTD: MID040
VTD: MID041
VTD: MID042
VTD: MID043
VTD: MID044
VTD: MID045
VTD: MID046
VTD: MID047
VTD: MID048
VTD: MID049
VTD: MID050
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
117a
SC101805 Appeal Document Number 6 Page 15
HB 1
470
471
472
473
474
475
476
477
478
479
480
481
482
483
484
485
486
487
488
489
490
491
492
493
494
495
496
497
498
499
500
501
502
503
504
505
506
15
VTD: MID051
VTD: MID052
VTD: MID053
VTD: MID054
VTD: MID055
VTD: MID056
VTD: MID057
VTD: MID058
VTD: MID059
VTD: MID060
VTD: MID061
VTD: MID200
VTD: MID201
VTD: MID202
VTD: MID204
VTD: NOR001
VTD: NOR002
VTD: NOR003
VTD: NOR004
VTD: NOR005
VTD: NOR006
VTD: NOR007
VTD: NOR008
VTD: NOR009
VTD: NOR010
VTD: NOR011
VTD: NOR012
VTD: NOR013
VTD: NOR014
VTD: NOR015
VTD: NOR016
VTD: NOR017
VTD: NOR018
VTD: NOR019
VTD: NOR020
VTD: NOR021
VTD: NOR022
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
118a
SC101805 Appeal Document Number 6 Page 16
HB 1
507
508
509
510
511
512
513
514
515
516
517
518
519
520
521
522
523
524
525
526
527
528
529
530
531
532
533
534
535
536
537
538
539
540
541
542
543
16
VTD: NOR023
VTD: NOR024
VTD: NOR025
VTD: NOR026
VTD: NOR027
VTD: NOR028
VTD: NOR029
VTD: NOR030
VTD: NOR031
VTD: NOR032
VTD: NOR033
VTD: NOR034
VTD: NOR035
VTD: NOR036
VTD: NOR037
VTD: NOR038
VTD: NOR039
VTD: NOR040
VTD: NOR041
VTD: NOR042
VTD: NOR043
VTD: NOR044
VTD: NOR045
VTD: NOR046
VTD: NOR047
VTD: NOR048
VTD: NOR049
VTD: NOR050
VTD: NOR051
VTD: NOR052
VTD: NOR053
VTD: NOR054
VTD: NOR055
VTD: NOR056
VTD: NOR200
VTD: NOR201
VTD: NOR202
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
119a
SC101805 Appeal Document Number 6 Page 17
HB 1
544
545
546
547
548
549
550
551
552
553
554
555
556
557
558
559
560
561
562
563
564
565
566
567
568
569
570
571
572
573
574
575
576
577
578
579
580
17
VTD: NOR203
VTD: NOR204
VTD: NOR208
VTD: NOR213
VTD: NOR218
VTD: NOR222
VTD: NRW001
VTD: NRW002
VTD: NRW003
VTD: NRW004
VTD: NRW005
VTD: NRW006
VTD: NRW007
VTD: NRW008
VTD: NRW009
VTD: NRW010
VTD: NRW011
VTD: NRW012
VTD: NRW013
VTD: NRW014
VTD: NRW015
VTD: NRW016
VTD: NRW017
VTD: NRW018
VTD: NRW019
VTD: NRW020
VTD: NRW021
VTD: NRW022
VTD: NRW023
VTD: NRW024
VTD: NRW025
VTD: NRW026
VTD: NRW027
VTD: NRW028
VTD: NRW029
VTD: NRW030
VTD: NRW031
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
120a
SC101805 Appeal Document Number 6 Page 18
HB 1
581
582
583
584
585
586
587
588
589
590
591
592
593
594
595
596
597
598
599
600
601
602
603
604
605
606
607
608
609
610
611
612
613
614
615
616
617
18
VTD: NRW032
VTD: NRW033
VTD: NRW034
VTD: NRW035
VTD: NRW036
VTD: NRW037
VTD: NRW038
VTD: NRW039
VTD: NRW040
VTD: NRW041
VTD: NRW042
VTD: NRW043
VTD: NRW044
VTD: NRW045
VTD: NRW046
VTD: NRW047
VTD: NRW048
VTD: NRW049
VTD: NRW050
VTD: NRW051
VTD: NRW200
VTD: NRW201
VTD: NRW202
VTD: NRW203
VTD: NRW204
VTD: NRW205
VTD: NW001
Block: 291892132023002
VTD NW001 Subtotal
VTD: NW002
VTD: NW003
VTD: NW004
VTD: NW005
VTD: NW006
VTD: NW007
VTD: NW008
VTD: NW009
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
121a
SC101805 Appeal Document Number 6 Page 19
HB 1
618
619
620
621
622
623
624
625
626
627
628
629
630
631
632
633
634
635
636
637
638
639
640
641
642
643
644
645
646
647
648
649
650
651
652
653
654
19
VTD: NW010
VTD: NW011
VTD: NW012
VTD: NW014
VTD: NW015
VTD: NW016
VTD: NW017
VTD: NW018
VTD: NW022
VTD: NW023
VTD: NW024
VTD: NW025
VTD: NW026
VTD: NW027
VTD: NW028
VTD: NW030
VTD: NW031
VTD: NW032
VTD: NW034
VTD: NW036
VTD: NW037
VTD: NW039
VTD: NW040
VTD: NW041
VTD: NW042
VTD: NW043
VTD: NW044
VTD: NW045
VTD: NW046
VTD: NW048
VTD: NW050
VTD: NW051
VTD: NW200
VTD: NW202
VTD: NW204
VTD: NW205
VTD: NW206
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
122a
SC101805 Appeal Document Number 6 Page 20
HB 1
655
656
657
658
659
660
661
662
663
664
665
666
667
668
669
670
671
672
673
674
675
676
677
678
679
680
681
682
683
684
685
686
687
688
689
690
691
20
VTD: NW207
VTD: NW208
VTD: NW209
VTD: NW210
VTD: NW212
VTD: NW213
VTD: NW214
VTD: NW215
VTD: NW216
VTD: NW217
VTD: NW219
VTD: NW220
Block: 291892132031024
VTD NW220 Subtotal
VTD: NW224
VTD: NW225
VTD: NW226
VTD: NW227
VTD: NW229
VTD: SF001
VTD: SF002
VTD: SF003
VTD: SF004
VTD: SF005
VTD: SF006
VTD: SF007
VTD: SF008
VTD: SF009
VTD: SF010
VTD: SF011
VTD: SF012
VTD: SF013
VTD: SF014
VTD: SF015
VTD: SF016
VTD: SF017
VTD: SF018
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
123a
SC101805 Appeal Document Number 6 Page 21
HB 1
692
693
694
695
696
697
698
699
700
701
702
703
704
705
706
707
708
709
710
711
712
713
714
715
716
717
718
719
720
721
722
723
724
725
726
727
728
21
VTD: SF019
VTD: SF020
VTD: SF021
VTD: SF022
VTD: SF023
VTD: SF024
VTD: SF025
VTD: SF026
VTD: SF027
VTD: SF028
VTD: SF029
VTD: SF030
VTD: SF031
VTD: SF032
VTD: SF033
VTD: SF034
VTD: SF035
VTD: SF200
VTD: SPL001
VTD: SPL002
VTD: SPL003
VTD: SPL004
VTD: SPL005
VTD: SPL006
VTD: SPL007
VTD: SPL008
VTD: SPL009
VTD: SPL010
VTD: SPL011
VTD: SPL012
VTD: SPL013
VTD: SPL014
VTD: SPL015
VTD: SPL016
VTD: SPL017
VTD: SPL018
VTD: SPL019
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
124a
SC101805 Appeal Document Number 6 Page 22
HB 1
729
730
731
732
733
734
735
736
737
738
739
740
741
742
743
744
745
746
747
748
749
750
751
752
753
754
755
756
757
758
759
760
761
762
763
764
765
22
VTD: SPL020
VTD: SPL021
VTD: SPL022
VTD: SPL023
VTD: SPL024
VTD: SPL025
VTD: SPL026
VTD: SPL027
VTD: SPL028
VTD: SPL201
VTD: SPL202
VTD: SPL207
VTD: SPL208
VTD: UNV001
VTD: UNV002
VTD: UNV003
VTD: UNV004
VTD: UNV005
VTD: UNV006
VTD: UNV007
VTD: UNV008
VTD: UNV009
VTD: UNV010
VTD: UNV011
VTD: UNV012
VTD: UNV013
VTD: UNV014
VTD: UNV015
VTD: UNV016
VTD: UNV017
VTD: UNV018
VTD: UNV019
VTD: UNV020
VTD: UNV021
VTD: UNV022
VTD: UNV023
VTD: UNV024
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
125a
SC101805 Appeal Document Number 6 Page 23
HB 1
766
767
768
769
770
771
772
773
774
775
776
777
778
779
780
781
782
783
784
785
786
787
788
789
790
791
792
2
3
4
5
6
7
8
9
10
23
VTD: UNV025
VTD: UNV026
VTD: UNV027
VTD: UNV028
VTD: UNV029
VTD: UNV030
VTD: UNV031
VTD: UNV032
VTD: UNV033
VTD: UNV034
VTD: UNV035
VTD: UNV036
VTD: UNV037
VTD: UNV038
VTD: UNV039
VTD: UNV040
VTD: UNV041
VTD: UNV042
VTD: UNV043
VTD: UNV045
VTD: UNV201
VTD: UNV202
VTD: UNV205
VTD: UNV206
VTD: UNV208
County St. Louis MO Subtotal
District 1 Total
128.472. The second congressional district shall be composed of the following:
County: Crawford MO
County: Franklin MO
County: Gasconade MO
County: Jefferson MO
VTD: Brennan
Block: 290997002111020
Block: 290997002111021
Block: 290997003032017
Block: 290997003051001
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
126a
SC101805 Appeal Document Number 6 Page 24
HB 1
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
24
Block: 290997003051003
Block: 290997003052001
Block: 290997003052002
Block: 290997003052003
Block: 290997003052004
Block: 290997003052005
Block: 290997003052025
VTD Brennan Subtotal
VTD: Byrnes Mill W-1
VTD: Byrnes Mill W-2
VTD: Byrnes Mill W-3
VTD: Byrnesville
VTD: Cedar Hill
VTD: Cedar Hill Lakes
VTD: De Soto W-1
VTD: De Soto W-2
VTD: De Soto W-3
VTD: De Soto W-4
VTD: Dulin Creek
VTD: Goldman
VTD: Grubville
VTD: Grubville 2
VTD: High Ridge
VTD: Hillsboro W-1
VTD: Hillsboro W-2
VTD: Hillsboro W-3
VTD: Hillsboro W-4
VTD: Hoene Springs
VTD: House Springs
VTD: Lake Tekawitha
VTD: Lake Tishomingo
VTD: Meramec Valley
VTD: North Jefferson
Block: 290997002062004
Block: 290997002062005
Block: 290997002072000
Block: 290997002072001
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
127a
SC101805 Appeal Document Number 6 Page 25
HB 1
48
49
50
51
52
53
54
55
56
57
58
59
60
61
62
63
64
65
66
67
68
69
70
71
72
73
74
75
76
77
78
79
80
81
82
83
84
25
Block: 290997002072002
Block: 290997002072003
Block: 290997002072004
Block: 290997002072005
Block: 290997002072006
Block: 290997002072007
Block: 290997002072008
Block: 290997002072009
Block: 290997002072010
Block: 290997002072011
Block: 290997002072012
Block: 290997002072013
Block: 290997002072014
Block: 290997002072017
Block: 290997002072018
Block: 290997002072019
Block: 290997002072020
Block: 290997002072021
Block: 290997002072022
Block: 290997002072023
Block: 290997002072024
Block: 290997002072025
Block: 290997002111019
Block: 290997002113004
Block: 290997002113005
Block: 290997002113006
Block: 290997002113007
Block: 290997002113008
Block: 290997002113009
Block: 290997002113012
Block: 290997002113013
Block: 290997002113014
Block: 290997002113015
Block: 290997002113016
Block: 290997002113017
Block: 290997002113019
Block: 290997003022000
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
128a
SC101805 Appeal Document Number 6 Page 26
HB 1
85
86
87
88
89
90
91
92
93
94
95
96
97
98
99
100
101
102
103
104
105
106
107
108
109
110
111
112
113
114
115
116
117
118
119
120
121
26
Block: 290997003022001
Block: 290997003022002
Block: 290997003022015
Block: 290997003023002
Block: 290997003063001
Block: 290997003063003
Block: 290997003063004
Block: 290997003063005
VTD North Jefferson Subtotal
VTD: Northwest
VTD: Parkdale
VTD: Peaceful Village
VTD: Raintree
VTD: Rockwood
VTD: Scotsdale
VTD: Valle
Block: 290997010023040
Block: 290997010023041
Block: 290997012006047
Block: 290997012006053
Block: 290997012006061
Block: 290997012006062
Block: 290997013001001
Block: 290997013001002
Block: 290997013001003
Block: 290997013001004
Block: 290997013001055
Block: 290997013001062
Block: 290997013001063
Block: 290997013001064
Block: 290997013001065
Block: 290997013001066
Block: 290997013001067
Block: 290997013001070
Block: 290997013001075
Block: 290997013001077
Block: 290997013003003
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
129a
SC101805 Appeal Document Number 6 Page 27
HB 1
122
123
124
125
126
127
128
129
130
131
132
133
134
135
136
137
138
139
140
141
142
143
144
145
146
147
148
149
150
151
152
153
154
155
156
157
158
27
Block: 290997013003013
Block: 290997013003014
Block: 290997013003015
Block: 290997013003017
Block: 290997013003018
Block: 290997013003019
Block: 290997013003021
Block: 290997013003022
Block: 290997014012008
Block: 290997014012009
Block: 290997014012017
Block: 290997014012021
Block: 290997014012022
Block: 290997014012023
Block: 290997014012064
Block: 290997014012065
Block: 290997014012066
Block: 290997014012067
VTD Valle Subtotal
VTD: Victoria
Block: 290997010011036
Block: 290997010013008
Block: 290997010013032
Block: 290997010013033
Block: 290997010021020
Block: 290997010021022
Block: 290997010021023
Block: 290997010021024
Block: 290997010022000
Block: 290997010022001
Block: 290997010022002
Block: 290997010022003
Block: 290997010022004
Block: 290997010022005
Block: 290997010022006
Block: 290997010022007
Block: 290997010022010
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
130a
SC101805 Appeal Document Number 6 Page 28
HB 1
159
160
161
162
163
164
165
166
167
168
169
170
171
172
173
174
175
176
177
178
179
180
181
182
183
184
185
186
187
188
189
190
191
192
193
194
195
28
Block: 290997010022011
Block: 290997010022012
Block: 290997010022017
Block: 290997010022018
Block: 290997010022020
Block: 290997010022021
Block: 290997010022022
Block: 290997010022024
Block: 290997010022025
Block: 290997010022026
Block: 290997010022027
Block: 290997010022029
Block: 290997010022030
Block: 290997010023007
Block: 290997010023008
Block: 290997010023009
Block: 290997010023010
Block: 290997010023011
Block: 290997010023014
Block: 290997010023015
Block: 290997010023016
Block: 290997010023017
Block: 290997010023018
Block: 290997010023022
Block: 290997010023023
Block: 290997010023024
Block: 290997010023025
Block: 290997010023026
Block: 290997010023027
Block: 290997010023028
Block: 290997010023032
Block: 290997010023033
Block: 290997010023034
Block: 290997010023036
Block: 290997010023037
Block: 290997012001000
Block: 290997012001028
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
131a
SC101805 Appeal Document Number 6 Page 29
HB 1
196
197
198
199
200
201
202
203
204
205
206
207
208
209
210
211
212
213
214
215
216
217
218
219
220
221
222
223
224
225
226
227
228
229
230
231
232
29
Block: 290997012001029
Block: 290997012001030
VTD Victoria Subtotal
VTD: Vineland
VTD: Ware
County Jefferson MO Subtotal
County: St. Louis MO
VTD: AP032
VTD: AP041
VTD: AP201
VTD: AP202
VTD: BON001
VTD: BON002
VTD: BON003
VTD: BON004
VTD: BON005
VTD: BON006
VTD: BON007
VTD: BON008
VTD: BON009
VTD: BON010
VTD: BON011
VTD: BON012
VTD: BON013
VTD: BON014
VTD: BON015
VTD: BON016
VTD: BON017
VTD: BON018
VTD: BON019
VTD: BON020
VTD: BON021
VTD: BON022
VTD: BON023
VTD: BON024
VTD: BON025
VTD: BON026
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
132a
SC101805 Appeal Document Number 6 Page 30
HB 1
233
234
235
236
237
238
239
240
241
242
243
244
245
246
247
248
249
250
251
252
253
254
255
256
257
258
259
260
261
262
263
264
265
266
267
268
269
30
VTD: BON027
VTD: BON028
VTD: BON029
VTD: BON030
VTD: BON031
VTD: BON032
VTD: BON033
VTD: BON034
VTD: BON035
VTD: BON036
VTD: BON037
VTD: BON038
VTD: BON039
VTD: BON040
VTD: BON200
VTD: BON202
VTD: BON203
VTD: BON205
VTD: BON206
VTD: BON207
VTD: BON208
VTD: BON210
VTD: BON211
VTD: CC001
VTD: CC002
VTD: CC003
VTD: CC004
VTD: CC005
VTD: CC006
VTD: CC007
VTD: CC008
VTD: CC009
VTD: CC010
VTD: CC011
VTD: CC014
VTD: CC015
VTD: CC016
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
133a
SC101805 Appeal Document Number 6 Page 31
HB 1
270
271
272
273
274
275
276
277
278
279
280
281
282
283
284
285
286
287
288
289
290
291
292
293
294
295
296
297
298
299
300
301
302
303
304
305
306
31
VTD: CC017
VTD: CC018
VTD: CC019
VTD: CC020
VTD: CC021
VTD: CC023
VTD: CC024
VTD: CC025
VTD: CC026
VTD: CC027
VTD: CC028
VTD: CC029
VTD: CC030
VTD: CC031
VTD: CC032
VTD: CC033
VTD: CC034
VTD: CC035
VTD: CC036
VTD: CC037
VTD: CC038
VTD: CC039
VTD: CC040
VTD: CC041
VTD: CC042
VTD: CC044
VTD: CC045
VTD: CC046
VTD: CC047
VTD: CC048
Block: 291892155001007
Block: 291892155004013
Block: 291892155004014
Block: 291892155004015
Block: 291892155004016
Block: 291892155004017
VTD CC048 Subtotal
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
134a
SC101805 Appeal Document Number 6 Page 32
HB 1
307
308
309
310
311
312
313
314
315
316
317
318
319
320
321
322
323
324
325
326
327
328
329
330
331
332
333
334
335
336
337
338
339
340
341
342
343
32
VTD: CC049
VTD: CC050
VTD: CC052
VTD: CC053
VTD: CC054
VTD: CC055
VTD: CC056
VTD: CC058
VTD: CC059
VTD: CC060
VTD: CC201
VTD: CC202
VTD: CC203
Block: 291892156001020
Block: 291892156001021
Block: 291892156001024
Block: 291892156001025
Block: 291892156001026
Block: 291892156001029
Block: 291892156001030
VTD CC203 Subtotal
VTD: CC208
VTD: CC214
VTD: CC221
VTD: CHE001
VTD: CHE002
VTD: CHE003
VTD: CHE004
VTD: CHE005
VTD: CHE006
VTD: CHE007
VTD: CHE008
VTD: CHE009
VTD: CHE010
VTD: CHE011
VTD: CHE012
VTD: CHE013
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
135a
SC101805 Appeal Document Number 6 Page 33
HB 1
344
345
346
347
348
349
350
351
352
353
354
355
356
357
358
359
360
361
362
363
364
365
366
367
368
369
370
371
372
373
374
375
376
377
378
379
380
33
VTD: CHE014
VTD: CHE015
VTD: CHE016
VTD: CHE017
VTD: CHE018
VTD: CHE019
VTD: CHE020
VTD: CHE021
VTD: CHE022
VTD: CHE023
VTD: CHE024
VTD: CHE025
VTD: CHE026
VTD: CHE027
VTD: CHE028
VTD: CHE029
VTD: CHE030
VTD: CHE031
VTD: CHE032
VTD: CHE033
VTD: CHE034
VTD: CHE035
VTD: CHE036
VTD: CHE037
VTD: CHE038
VTD: CHE039
VTD: CHE040
VTD: CHE041
VTD: CHE042
VTD: CHE043
VTD: CHE044
VTD: CHE045
VTD: CHE046
VTD: CHE047
VTD: CHE048
VTD: CHE049
VTD: CHE050
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
136a
SC101805 Appeal Document Number 6 Page 34
HB 1
381
382
383
384
385
386
387
388
389
390
391
392
393
394
395
396
397
398
399
400
401
402
403
404
405
406
407
408
409
410
411
412
413
414
415
416
417
34
VTD: CHE051
VTD: CHE052
VTD: CHE053
VTD: CHE054
VTD: CHE055
VTD: CHE057
VTD: CHE200
VTD: CHE203
VTD: CHE212
VTD: CHE214
VTD: CHE215
VTD: CLA004
Block: 291892154004014
VTD CLA004 Subtotal
VTD: CLA006
VTD: CLA007
VTD: CLA012
VTD: CLA013
Block: 291892154003013
Block: 291892154003014
Block: 291892154004000
Block: 291892154004001
Block: 291892154004002
Block: 291892154004003
Block: 291892154004004
Block: 291892154004008
Block: 291892154004012
Block: 291892154004013
Block: 291892154005001
Block: 291892154005002
Block: 291892154005003
VTD CLA013 Subtotal
VTD: CLA014
VTD: CLA015
VTD: CLA016
VTD: CLA024
VTD: CLA025
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
137a
SC101805 Appeal Document Number 6 Page 35
HB 1
418
419
420
421
422
423
424
425
426
427
428
429
430
431
432
433
434
435
436
437
438
439
440
441
442
443
444
445
446
447
448
449
450
451
452
453
454
35
VTD: CLA026
VTD: CLA028
VTD: CLA033
VTD: CLA034
VTD: CLA036
VTD: CLA037
VTD: CLA040
VTD: CLA042
VTD: CLA045
VTD: CLA047
VTD: CLA049
VTD: CLA201
VTD: CLA202
VTD: CLA203
VTD: CLA205
VTD: CON001
VTD: CON002
VTD: CON003
VTD: CON004
VTD: CON005
VTD: CON006
VTD: CON007
VTD: CON008
VTD: CON009
VTD: CON010
VTD: CON011
VTD: CON012
VTD: CON013
VTD: CON014
VTD: CON015
VTD: CON016
VTD: CON017
VTD: CON018
VTD: CON019
VTD: CON020
VTD: CON021
VTD: CON022
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
138a
SC101805 Appeal Document Number 6 Page 36
HB 1
455
456
457
458
459
460
461
462
463
464
465
466
467
468
469
470
471
472
473
474
475
476
477
478
479
480
481
482
483
484
485
486
487
488
489
490
491
36
VTD: CON023
VTD: CON024
VTD: CON025
VTD: CON026
VTD: CON027
VTD: CON028
VTD: CON029
VTD: CON030
VTD: CON031
VTD: CON032
VTD: CON033
VTD: CON034
VTD: CON035
VTD: CON036
VTD: CON037
VTD: CON038
VTD: CON039
VTD: CON040
VTD: CON041
VTD: CON042
VTD: CON043
VTD: CON044
VTD: CON045
VTD: CON046
VTD: CON047
VTD: CON048
VTD: CON049
VTD: CON050
VTD: CON051
VTD: CON052
VTD: CON053
VTD: CON200
VTD: CON202
VTD: CON204
VTD: CON205
VTD: CON206
VTD: CON212
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
139a
SC101805 Appeal Document Number 6 Page 37
HB 1
492
493
494
495
496
497
498
499
500
501
502
503
504
505
506
507
508
509
510
511
512
513
514
515
516
517
518
519
520
521
522
523
524
525
526
527
528
37
VTD: CON213
VTD: GRA001
VTD: GRA002
VTD: GRA003
VTD: GRA004
VTD: GRA005
VTD: GRA006
VTD: GRA007
Block: 291892198011021
Block: 291892198012003
Block: 291892198012006
Block: 291892198012007
Block: 291892198012008
Block: 291892198012009
Block: 291892198012010
Block: 291892198012011
Block: 291892198012012
VTD GRA007 Subtotal
VTD: GRA008
VTD: GRA009
VTD: GRA010
VTD: GRA011
VTD: GRA012
VTD: GRA013
VTD: GRA014
VTD: GRA015
Block: 291892197004003
Block: 291892197004004
Block: 291892197004005
Block: 291892197004006
Block: 291892197004007
Block: 291892197004008
Block: 291892197004009
Block: 291892208013000
Block: 291892208013001
Block: 291892208013002
Block: 291892208013003
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
140a
SC101805 Appeal Document Number 6 Page 38
HB 1
529
530
531
532
533
534
535
536
537
538
539
540
541
542
543
544
545
546
547
548
549
550
551
552
553
554
555
556
557
558
559
560
561
562
563
564
565
38
Block: 291892208013004
Block: 291892208013005
Block: 291892208013006
Block: 291892208013007
Block: 291892208013008
Block: 291892208013009
VTD GRA015 Subtotal
VTD: GRA017
VTD: GRA019
Block: 291892197004000
Block: 291892197004001
Block: 291892197004002
Block: 291892197004010
Block: 291892197004011
Block: 291892197004012
Block: 291892198012004
Block: 291892198012005
VTD GRA019 Subtotal
VTD: GRA020
VTD: GRA023
VTD: GRA024
VTD: GRA026
VTD: GRA027
VTD: GRA028
VTD: GRA029
VTD: GRA030
VTD: GRA031
VTD: GRA032
VTD: GRA033
Block: 291892199001007
Block: 291892199004000
Block: 291892199004001
Block: 291892199004002
Block: 291892199004003
Block: 291892199004004
VTD GRA033 Subtotal
VTD: GRA034
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
141a
SC101805 Appeal Document Number 6 Page 39
HB 1
566
567
568
569
570
571
572
573
574
575
576
577
578
579
580
581
582
583
584
585
586
587
588
589
590
591
592
593
594
595
596
597
598
599
600
601
602
39
VTD: GRA036
VTD: GRA037
VTD: GRA038
VTD: GRA040
VTD: GRA041
VTD: GRA042
VTD: GRA043
VTD: GRA044
VTD: GRA045
Block: 291892208011022
VTD GRA045 Subtotal
VTD: GRA046
VTD: GRA047
VTD: GRA048
VTD: GRA201
VTD: GRA202
Block: 291892208011017
VTD GRA202 Subtotal
VTD: GRA206
VTD: GRA209
VTD: GRA210
VTD: JEF001
VTD: JEF002
VTD: JEF003
VTD: JEF004
VTD: JEF010
Block: 291892219001008
VTD JEF010 Subtotal
VTD: JEF032
VTD: JEF033
VTD: JEF034
VTD: JEF035
VTD: JEF036
VTD: JEF037
VTD: JEF200
VTD: LAF001
VTD: LAF002
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
142a
SC101805 Appeal Document Number 6 Page 40
HB 1
603
604
605
606
607
608
609
610
611
612
613
614
615
616
617
618
619
620
621
622
623
624
625
626
627
628
629
630
631
632
633
634
635
636
637
638
639
40
VTD: LAF003
VTD: LAF004
VTD: LAF005
VTD: LAF006
VTD: LAF007
VTD: LAF008
VTD: LAF009
VTD: LAF010
VTD: LAF011
VTD: LAF012
VTD: LAF013
VTD: LAF014
VTD: LAF015
VTD: LAF016
VTD: LAF017
VTD: LAF018
VTD: LAF019
VTD: LAF020
VTD: LAF022
VTD: LAF023
VTD: LAF024
VTD: LAF025
VTD: LAF026
VTD: LAF027
VTD: LAF028
VTD: LAF029
VTD: LAF030
VTD: LAF031
VTD: LAF032
VTD: LAF033
VTD: LAF034
VTD: LAF035
VTD: LAF036
VTD: LAF037
VTD: LAF038
VTD: LAF039
VTD: LAF040
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
143a
SC101805 Appeal Document Number 6 Page 41
HB 1
640
641
642
643
644
645
646
647
648
649
650
651
652
653
654
655
656
657
658
659
660
661
662
663
664
665
666
667
668
669
670
671
672
673
674
675
676
41
VTD: LAF041
VTD: LAF042
VTD: LAF043
VTD: LAF044
VTD: LAF045
VTD: LAF046
VTD: LAF200
VTD: LAF205
VTD: LAF207
VTD: LEM001
VTD: LEM002
VTD: LEM003
VTD: LEM004
VTD: LEM005
VTD: LEM006
VTD: LEM007
VTD: LEM008
VTD: LEM009
VTD: LEM010
VTD: LEM011
VTD: LEM012
VTD: LEM013
VTD: LEM014
VTD: LEM015
VTD: LEM016
VTD: LEM017
VTD: LEM018
VTD: LEM019
VTD: LEM020
VTD: LEM021
VTD: LEM022
VTD: LEM023
VTD: LEM024
VTD: LEM025
VTD: LEM026
VTD: LEM027
VTD: LEM028
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
144a
SC101805 Appeal Document Number 6 Page 42
HB 1
677
678
679
680
681
682
683
684
685
686
687
688
689
690
691
692
693
694
695
696
697
698
699
700
701
702
703
704
705
706
707
708
709
710
711
712
713
42
VTD: LEM029
VTD: LEM030
VTD: LEM031
VTD: LEM032
VTD: LEM033
VTD: LEM200
VTD: LEM201
VTD: LEM202
VTD: LEM204
VTD: LEM205
VTD: LEM208
VTD: MER001
VTD: MER002
VTD: MER003
VTD: MER004
VTD: MER005
VTD: MER006
VTD: MER007
VTD: MER008
VTD: MER009
VTD: MER010
VTD: MER011
VTD: MER012
VTD: MER013
VTD: MER014
VTD: MER015
VTD: MER016
VTD: MER017
VTD: MER018
VTD: MER019
VTD: MER020
VTD: MER021
VTD: MER022
VTD: MER023
VTD: MER024
VTD: MER025
VTD: MER026
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
145a
SC101805 Appeal Document Number 6 Page 43
HB 1
714
715
716
717
718
719
720
721
722
723
724
725
726
727
728
729
730
731
732
733
734
735
736
737
738
739
740
741
742
743
744
745
746
747
748
749
750
43
VTD: MER027
VTD: MER028
VTD: MER029
VTD: MER030
VTD: MER031
VTD: MER032
VTD: MER033
VTD: MER034
VTD: MER035
VTD: MER036
VTD: MER037
VTD: MER038
VTD: MER039
VTD: MER040
VTD: MER041
VTD: MER042
VTD: MER043
VTD: MER044
VTD: MER045
VTD: MER046
VTD: MER047
VTD: MER048
VTD: MER200
VTD: MER202
VTD: MER204
VTD: MER207
VTD: MER209
VTD: MER210
VTD: MER213
VTD: MER214
VTD: MER215
VTD: MER219
VTD: MHT001
VTD: MHT002
VTD: MHT003
VTD: MHT004
VTD: MHT005
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
146a
SC101805 Appeal Document Number 6 Page 44
HB 1
751
752
753
754
755
756
757
758
759
760
761
762
763
764
765
766
767
768
769
770
771
772
773
774
775
776
777
778
779
780
781
782
783
784
785
786
787
44
VTD: MHT006
VTD: MHT007
VTD: MHT008
VTD: MHT009
VTD: MHT010
VTD: MHT011
VTD: MHT012
VTD: MHT013
VTD: MHT014
VTD: MHT015
VTD: MHT016
VTD: MHT017
VTD: MHT018
VTD: MHT019
VTD: MHT020
VTD: MHT021
VTD: MHT022
VTD: MHT023
VTD: MHT024
VTD: MHT025
VTD: MHT026
VTD: MHT027
VTD: MHT028
VTD: MHT029
VTD: MHT030
VTD: MHT031
VTD: MHT032
VTD: MHT033
VTD: MHT034
VTD: MHT035
VTD: MHT036
VTD: MHT037
VTD: MHT038
VTD: MHT039
VTD: MHT040
VTD: MHT041
VTD: MHT042
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
147a
SC101805 Appeal Document Number 6 Page 45
HB 1
788
789
790
791
792
793
794
795
796
797
798
799
800
801
802
803
804
805
806
807
808
809
810
811
812
813
814
815
816
817
818
819
820
821
822
823
824
45
VTD: MHT043
VTD: MHT044
VTD: MHT045
VTD: MHT046
VTD: MHT047
VTD: MHT048
VTD: MHT049
VTD: MHT050
VTD: MHT051
VTD: MHT052
VTD: MHT053
VTD: MHT054
VTD: MHT055
VTD: MHT056
VTD: MHT057
VTD: MHT058
VTD: MHT059
VTD: MHT200
VTD: MHT203
VTD: MHT206
VTD: MHT207
VTD: MHT208
VTD: MHT211
VTD: MHT212
VTD: MHT213
VTD: MHT214
VTD: MHT216
VTD: MHT219
VTD: MHT220
VTD: MHT222
VTD: MHT223
VTD: MR001
VTD: MR002
VTD: MR003
VTD: MR004
VTD: MR005
VTD: MR006
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
148a
SC101805 Appeal Document Number 6 Page 46
HB 1
825
826
827
828
829
830
831
832
833
834
835
836
837
838
839
840
841
842
843
844
845
846
847
848
849
850
851
852
853
854
855
856
857
858
859
860
861
46
VTD: MR007
VTD: MR008
VTD: MR009
VTD: MR010
VTD: MR011
VTD: MR012
VTD: MR013
VTD: MR014
VTD: MR015
VTD: MR016
VTD: MR017
VTD: MR018
VTD: MR019
VTD: MR020
VTD: MR021
VTD: MR022
VTD: MR023
VTD: MR024
VTD: MR025
VTD: MR026
VTD: MR027
VTD: MR028
VTD: MR029
VTD: MR030
VTD: MR031
VTD: MR032
VTD: MR033
VTD: MR034
VTD: MR035
VTD: MR036
VTD: MR037
VTD: MR038
VTD: MR039
VTD: MR040
VTD: MR041
VTD: MR042
VTD: MR043
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
149a
SC101805 Appeal Document Number 6 Page 47
HB 1
862
863
864
865
866
867
868
869
870
871
872
873
874
875
876
877
878
879
880
881
882
883
884
885
886
887
888
889
890
891
892
893
894
895
896
897
898
47
VTD: MR044
VTD: MR045
VTD: MR046
VTD: MR047
VTD: MR048
VTD: MR049
VTD: MR050
VTD: MR051
VTD: MR052
VTD: MR053
VTD: MR054
VTD: MR055
VTD: MR056
VTD: MR057
VTD: MR058
VTD: MR059
VTD: MR200
VTD: MR202
VTD: MR203
VTD: MR204
VTD: MR205
VTD: MR209
VTD: MR210
VTD: MR212
VTD: MR213
VTD: NW001
Block: 291892132023003
Block: 291892132023004
Block: 291892132023005
Block: 291892132023006
Block: 291892132023007
Block: 291892132023008
Block: 291892132023009
Block: 291892132025008
Block: 291892132025009
Block: 291892132025010
Block: 291892132025011
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
150a
SC101805 Appeal Document Number 6 Page 48
HB 1
899
900
901
902
903
904
905
906
907
908
909
910
911
912
913
914
915
916
917
918
919
920
921
922
923
924
925
926
927
928
929
930
931
932
933
934
935
48
Block: 291892132025012
Block: 291892132025013
Block: 291892132025014
Block: 291892132025015
VTD NW001 Subtotal
VTD: NW013
Block: 291892151431031
Block: 291892151431044
Block: 291892151431045
Block: 291892151431046
Block: 291892151431047
Block: 291892151431049
Block: 291892151431050
Block: 291892151431052
Block: 291892151431055
Block: 291892151431056
Block: 291892151431057
Block: 291892151431063
VTD NW013 Subtotal
VTD: NW019
VTD: NW020
VTD: NW029
VTD: NW033
VTD: NW035
Block: 291892151432000
Block: 291892151432011
Block: 291892151432012
Block: 291892151432013
Block: 291892151432017
Block: 291892151432018
Block: 291892151432019
Block: 291892151432020
Block: 291892151432021
Block: 291892151432022
Block: 291892151432023
VTD NW035 Subtotal
VTD: NW038
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
151a
SC101805 Appeal Document Number 6 Page 49
HB 1
936
937
938
939
940
941
942
943
944
945
946
947
948
949
950
951
952
953
954
955
956
957
958
959
960
961
962
963
964
965
966
967
968
969
970
971
972
49
VTD: NW047
VTD: NW049
VTD: NW052
VTD: NW201
VTD: NW211
VTD: OAK001
VTD: OAK002
VTD: OAK003
VTD: OAK004
VTD: OAK005
VTD: OAK006
VTD: OAK007
VTD: OAK008
VTD: OAK009
VTD: OAK010
VTD: OAK011
VTD: OAK012
VTD: OAK013
VTD: OAK014
VTD: OAK015
VTD: OAK016
VTD: OAK017
VTD: OAK018
VTD: OAK019
VTD: OAK020
VTD: OAK021
VTD: OAK022
VTD: OAK023
VTD: OAK024
VTD: OAK025
VTD: OAK026
VTD: OAK027
VTD: OAK028
VTD: OAK029
VTD: QUE001
VTD: QUE002
VTD: QUE003
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
152a
SC101805 Appeal Document Number 6 Page 50
HB 1
973
974
975
976
977
978
979
980
981
982
983
984
985
986
987
988
989
990
991
992
993
994
995
996
997
998
999
1000
1001
1002
1003
1004
1005
1006
1007
1008
1009
50
VTD: QUE004
VTD: QUE005
VTD: QUE006
VTD: QUE007
VTD: QUE008
VTD: QUE009
VTD: QUE010
VTD: QUE011
VTD: QUE012
VTD: QUE013
VTD: QUE014
VTD: QUE015
VTD: QUE016
VTD: QUE017
VTD: QUE018
VTD: QUE019
VTD: QUE020
VTD: QUE021
VTD: QUE022
VTD: QUE023
VTD: QUE024
VTD: QUE025
VTD: QUE026
VTD: QUE027
VTD: QUE028
VTD: QUE029
VTD: QUE030
VTD: QUE031
VTD: QUE032
VTD: QUE033
VTD: QUE034
VTD: QUE035
VTD: QUE036
VTD: QUE037
VTD: QUE038
VTD: QUE039
VTD: QUE040
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
153a
SC101805 Appeal Document Number 6 Page 51
HB 1
1010
1011
1012
1013
1014
1015
1016
1017
1018
1019
1020
1021
1022
1023
1024
1025
1026
1027
1028
1029
1030
1031
1032
1033
1034
1035
1036
1037
1038
1039
1040
1041
1042
1043
1044
1045
1046
51
VTD: QUE041
VTD: QUE042
VTD: QUE043
VTD: QUE044
VTD: QUE045
VTD: QUE046
VTD: QUE047
VTD: QUE048
VTD: QUE049
VTD: QUE200
VTD: QUE201
VTD: QUE202
VTD: QUE203
VTD: QUE204
VTD: QUE205
VTD: QUE207
VTD: QUE208
VTD: QUE209
VTD: QUE210
VTD: QUE211
VTD: QUE213
VTD: TSF001
VTD: TSF002
VTD: TSF003
VTD: TSF004
VTD: TSF005
VTD: TSF006
VTD: TSF007
VTD: TSF008
VTD: TSF009
VTD: TSF010
VTD: TSF011
VTD: TSF012
VTD: TSF013
VTD: TSF014
VTD: TSF015
VTD: TSF016
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
154a
SC101805 Appeal Document Number 6 Page 52
HB 1
1047
1048
1049
1050
1051
1052
1053
1054
1055
1056
1057
1058
1059
1060
1061
1062
1063
1064
1065
1066
1067
1068
1069
1070
1071
1072
1073
1074
1075
1076
1077
1078
1079
1080
1081
1082
1083
52
VTD: TSF017
VTD: TSF018
VTD: TSF019
VTD: TSF020
VTD: TSF021
VTD: TSF022
VTD: TSF023
VTD: TSF024
VTD: TSF025
VTD: TSF026
VTD: TSF027
VTD: TSF201
VTD: WH001
VTD: WH002
VTD: WH003
VTD: WH004
VTD: WH005
VTD: WH006
VTD: WH007
VTD: WH008
VTD: WH009
VTD: WH010
VTD: WH011
VTD: WH012
VTD: WH013
VTD: WH014
VTD: WH015
VTD: WH016
VTD: WH017
VTD: WH018
VTD: WH019
VTD: WH020
VTD: WH021
VTD: WH022
VTD: WH023
VTD: WH024
VTD: WH025
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
155a
SC101805 Appeal Document Number 6 Page 53
HB 1
1084
1085
1086
1087
1088
1089
1090
1091
1092
1093
1094
1095
1096
1097
1098
1099
1100
1101
1102
1103
1104
1105
1106
1107
1108
1109
1110
1111
1112
1113
2
3
4
5
6
7
53
VTD: WH026
VTD: WH027
VTD: WH028
VTD: WH029
VTD: WH030
VTD: WH031
VTD: WH032
VTD: WH033
VTD: WH034
VTD: WH035
VTD: WH036
VTD: WH037
VTD: WH038
VTD: WH039
VTD: WH040
VTD: WH041
VTD: WH042
VTD: WH043
VTD: WH044
VTD: WH045
VTD: WH046
VTD: WH047
VTD: WH200
VTD: WH201
VTD: WH202
VTD: WH203
VTD: WH208
County St. Louis MO Subtotal
County: Washington MO
District 2 Total
128.473. The third congressional district shall be composed of the following:
District 3
County: Audrain MO
County: Boone MO
VTD: 17
Block: 290190015062014
Block: 290190015062023
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
156a
SC101805 Appeal Document Number 6 Page 54
HB 1
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
54
Block: 290190015062031
VTD 17 Subtotal
VTD: 1A
VTD: 1B
VTD: 1C
VTD: 1D
VTD: 1E
VTD: 1F
VTD: 1G
VTD: 1I
VTD: 1J
VTD: 1K
VTD: 1L
VTD: 1M
VTD: 20
Block: 290190014024009
Block: 290190014024010
VTD 20 Subtotal
VTD: 21
Block: 290190013003006
Block: 290190013003008
Block: 290190013003009
Block: 290190013003023
Block: 290190018061001
Block: 290190018061002
Block: 290190018061003
Block: 290190018061004
Block: 290190018061008
Block: 290190018061009
Block: 290190018061010
Block: 290190018061011
Block: 290190018061012
Block: 290190018061016
Block: 290190018061017
VTD 21 Subtotal
VTD: 22
Block: 290190014013035
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
157a
SC101805 Appeal Document Number 6 Page 55
HB 1
45
46
47
48
49
50
51
52
53
54
55
56
57
58
59
60
61
62
63
64
65
66
67
68
69
70
71
72
73
74
75
76
77
78
79
80
81
55
Block: 290190014013036
Block: 290190014013041
Block: 290190014013045
Block: 290190014013046
VTD 22 Subtotal
VTD: 23
VTD: 24
VTD: 25
VTD: 26
VTD: 27
VTD: 28
VTD: 29
VTD: 2A
VTD: 2B
VTD: 2C
VTD: 2D
VTD: 2F
VTD: 2G
VTD: 2H
VTD: 2I
Block: 290190014011007
Block: 290190014011008
Block: 290190014011009
Block: 290190014011010
Block: 290190014011011
Block: 290190014011012
Block: 290190014011013
Block: 290190014011014
Block: 290190014011015
Block: 290190014011016
Block: 290190014011017
Block: 290190014011018
Block: 290190014011019
Block: 290190014011020
Block: 290190014012014
Block: 290190014012017
Block: 290190014012022
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
158a
SC101805 Appeal Document Number 6 Page 56
HB 1
82
83
84
85
86
87
88
89
90
91
92
93
94
95
96
97
98
99
100
101
102
103
104
105
106
107
108
109
110
111
112
113
114
115
116
117
118
56
Block: 290190014012023
Block: 290190014012024
Block: 290190014012025
Block: 290190014012026
Block: 290190014012029
Block: 290190014012030
Block: 290190014013007
Block: 290190014013008
Block: 290190014013009
Block: 290190014013010
Block: 290190014013011
Block: 290190014013013
Block: 290190014013014
Block: 290190014013015
Block: 290190014013016
Block: 290190014013018
Block: 290190014013019
Block: 290190014013020
Block: 290190014013021
Block: 290190014013022
Block: 290190014013023
Block: 290190014013024
Block: 290190014013034
Block: 290190014013037
Block: 290190014013038
Block: 290190014013039
Block: 290190014013040
Block: 290190014013042
Block: 290190014013043
Block: 290190014013044
Block: 290190014013047
Block: 290190014013052
Block: 290190014013058
Block: 290190015033022
VTD 2I Subtotal
VTD: 2J
VTD: 2K
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
159a
SC101805 Appeal Document Number 6 Page 57
HB 1
119
120
121
122
123
124
125
126
127
128
129
130
131
132
133
134
135
136
137
138
139
140
141
142
143
144
145
146
147
148
149
150
151
152
153
154
155
57
Block: 290190013003002
Block: 290190013003005
Block: 290190013003007
Block: 290190013003010
Block: 290190013003024
Block: 290190013003025
Block: 290190013003026
Block: 290190013003027
VTD 2K Subtotal
VTD: 2L
VTD: 30
VTD: 31
VTD: 32
VTD: 33
VTD: 34
VTD: 35
VTD: 36
VTD: 37
Block: 290190018062044
Block: 290190018062048
Block: 290190018062049
Block: 290190018062053
VTD 37 Subtotal
VTD: 3A
Block: 290190015031010
Block: 290190015031011
Block: 290190015031014
Block: 290190015031015
Block: 290190015031016
Block: 290190015031017
Block: 290190015031018
Block: 290190015031019
Block: 290190015031020
Block: 290190015032000
Block: 290190015032003
Block: 290190015032004
Block: 290190015032005
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
160a
SC101805 Appeal Document Number 6 Page 58
HB 1
156
157
158
159
160
161
162
163
164
165
166
167
168
169
170
171
172
173
174
175
176
177
178
179
180
181
182
183
184
185
186
187
188
189
190
191
192
58
Block: 290190015032006
Block: 290190015032007
Block: 290190015032008
Block: 290190015032009
Block: 290190015032010
Block: 290190015032011
Block: 290190015032012
Block: 290190015032013
Block: 290190015032014
Block: 290190015062027
Block: 290190015062028
Block: 290190015062032
Block: 290190015073001
Block: 290190015073002
Block: 290190015073003
Block: 290190015073006
Block: 290190015073007
Block: 290190015073008
Block: 290190015073009
Block: 290190015073010
Block: 290190015073011
Block: 290190015081002
Block: 290190015081003
Block: 290190015081017
Block: 290190015081018
Block: 290190015081019
Block: 290190015081020
Block: 290190015081024
Block: 290190015081025
Block: 290190015081026
Block: 290190015081027
Block: 290190015081028
Block: 290190015081029
Block: 290190015081030
VTD 3A Subtotal
VTD: 3B
Block: 290190015032001
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
161a
SC101805 Appeal Document Number 6 Page 59
HB 1
193
194
195
196
197
198
199
200
201
202
203
204
205
206
207
208
209
210
211
212
213
214
215
216
217
218
219
220
221
222
223
224
225
226
227
228
229
59
Block: 290190015032002
Block: 290190015052002
Block: 290190015052003
Block: 290190015061000
Block: 290190015061001
Block: 290190015061002
Block: 290190015061003
Block: 290190015061004
Block: 290190015061005
Block: 290190015061006
Block: 290190015061007
Block: 290190015061008
Block: 290190015061009
Block: 290190015061010
Block: 290190015061011
Block: 290190015061012
Block: 290190015061013
Block: 290190015061014
Block: 290190015061015
Block: 290190015061016
Block: 290190015061017
Block: 290190015061018
Block: 290190015061019
Block: 290190015061020
Block: 290190015061021
Block: 290190015061022
Block: 290190015061023
Block: 290190015061027
Block: 290190015061030
Block: 290190015062005
Block: 290190015062013
Block: 290190015062015
Block: 290190015062016
Block: 290190015062022
Block: 290190015062024
Block: 290190015062026
Block: 290190015062029
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
162a
SC101805 Appeal Document Number 6 Page 60
HB 1
230
231
232
233
234
235
236
237
238
239
240
241
242
243
244
245
246
247
248
249
250
251
252
253
254
255
256
257
258
259
260
261
262
263
264
265
266
60
Block: 290190015062033
Block: 290190015062034
Block: 290190015062035
Block: 290190015062036
Block: 290190015062037
Block: 290190015062038
Block: 290190015062039
Block: 290190015062040
Block: 290190015062041
Block: 290190015062042
Block: 290190015062043
Block: 290190015062044
Block: 290190015062045
Block: 290190015062046
Block: 290190015071022
Block: 290190015071023
Block: 290190015071024
Block: 290190015073004
Block: 290190015073005
Block: 290190015073012
Block: 290190016031015
Block: 290190016031016
VTD 3B Subtotal
VTD: 3C
VTD: 3D
VTD: 3E
VTD: 3F
VTD: 3G
VTD: 3H
VTD: 3I
VTD: 3J
VTD: 3L
VTD: 3M
VTD: 3N
VTD: 40
Block: 290190015081004
Block: 290190015081005
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
163a
SC101805 Appeal Document Number 6 Page 61
HB 1
267
268
269
270
271
272
273
274
275
276
277
278
279
280
281
282
283
284
285
286
287
288
289
290
291
292
293
294
295
296
297
298
299
300
301
302
303
61
Block: 290190015083016
Block: 290190015083024
VTD 40 Subtotal
VTD: 41
VTD: 42
VTD: 43
VTD: 44
VTD: 45
Block: 290190015033036
Block: 290190015033037
Block: 290190015083007
Block: 290190015083008
VTD 45 Subtotal
VTD: 4A
VTD: 4B
Block: 290190012013004
Block: 290190012013005
Block: 290190012013006
Block: 290190012013007
Block: 290190012013008
Block: 290190012013034
Block: 290190012014018
VTD 4B Subtotal
VTD: 4C
VTD: 4D
VTD: 4E
VTD: 4F
VTD: 4G
VTD: 4H
VTD: 4I
VTD: 4J
VTD: 4K
Block: 290190018061000
Block: 290190018061005
Block: 290190018061006
Block: 290190018061013
Block: 290190018063001
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
164a
SC101805 Appeal Document Number 6 Page 62
HB 1
304
305
306
307
308
309
310
311
312
313
314
315
316
317
318
319
320
321
322
323
324
325
326
327
328
329
330
331
332
333
334
335
336
337
338
339
340
62
Block: 290190018071017
Block: 290190018071018
Block: 290190018071021
Block: 290190018071029
Block: 290190018071030
Block: 290190018071031
Block: 290190018072024
Block: 290190018072025
Block: 290190018072028
Block: 290190018072029
Block: 290190018072030
Block: 290190018072031
Block: 290190018072032
Block: 290190018072033
Block: 290190018072034
Block: 290190018072035
Block: 290190018072036
Block: 290190018072037
VTD 4K Subtotal
VTD: 4L
Block: 290190012013009
Block: 290190012013010
Block: 290190012013011
Block: 290190012014002
Block: 290190012014003
Block: 290190012014004
Block: 290190012014005
Block: 290190012014006
Block: 290190012014007
Block: 290190012014008
Block: 290190012014009
Block: 290190012014010
Block: 290190012014011
Block: 290190012014012
Block: 290190012014013
Block: 290190012014014
Block: 290190012014019
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
165a
SC101805 Appeal Document Number 6 Page 63
HB 1
341
342
343
344
345
346
347
348
349
350
351
352
353
354
355
356
357
358
359
360
361
362
363
364
365
366
367
368
369
370
371
372
373
374
375
376
377
63
Block: 290190012014020
Block: 290190012014021
Block: 290190012014022
Block: 290190012014023
Block: 290190012014024
Block: 290190012014025
Block: 290190012014026
VTD 4L Subtotal
VTD: 4M
VTD: 5A
VTD: 5B
VTD: 5C
VTD: 5D
VTD: 5E
VTD: 5F
VTD: 5G
VTD: 5H
VTD: 5I
VTD: 5J
VTD: 5K
VTD: 5L
VTD: 5M
VTD: 5N
VTD: 5P
VTD: 6A
VTD: 6B
VTD: 6C
VTD: 6D
VTD: 6E
VTD: 6F
VTD: 6G
VTD: 6H
VTD: 6I
VTD: 6J
VTD: 6K
VTD: 6L
VTD: 6M
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
166a
SC101805 Appeal Document Number 6 Page 64
HB 1
378
379
380
381
382
383
384
385
386
387
388
389
390
391
392
393
394
395
396
397
398
399
400
401
402
403
404
405
406
407
408
409
410
411
412
413
414
64
County Boone MO Subtotal
County: Callaway MO
County: Lincoln MO
County: Monroe MO
County: Montgomery MO
County: Pike MO
County: Ralls MO
County: St. Charles MO
County: St. Louis MO
VTD: NW013
Block: 291892151431003
Block: 291892151431005
Block: 291892151431006
Block: 291892151431007
Block: 291892151431008
Block: 291892151431009
Block: 291892151431010
Block: 291892151431011
Block: 291892151431012
Block: 291892151431013
Block: 291892151431014
Block: 291892151431015
Block: 291892151431016
Block: 291892151431019
Block: 291892151431020
Block: 291892151431021
Block: 291892151431024
Block: 291892151431025
Block: 291892151431026
Block: 291892151431027
Block: 291892151431029
Block: 291892151431030
Block: 291892151431033
Block: 291892151431048
Block: 291892151431051
Block: 291892151431053
Block: 291892151431054
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
167a
SC101805 Appeal Document Number 6 Page 65
HB 1
415
416
417
418
419
420
421
422
423
424
425
426
427
428
429
430
431
432
433
434
435
436
437
438
439
2
3
4
5
6
7
8
9
10
11
12
65
Block: 291892151431064
VTD NW013 Subtotal
VTD: NW021
VTD: NW035
Block: 291892151432001
Block: 291892151432002
Block: 291892151432003
Block: 291892151432004
Block: 291892151432005
Block: 291892151432006
Block: 291892151432007
Block: 291892151432008
Block: 291892151432009
Block: 291892151432010
Block: 291892151432014
Block: 291892151432015
Block: 291892151432016
VTD NW035 Subtotal
VTD: NW203
VTD: NW220
Block: 291892132031027
VTD NW220 Subtotal
County St. Louis MO Subtotal
County: Warren MO
District 3 Total
128.474. The fourth congressional district shall be composed of the following:
County: Barton MO
County: Bates MO
County: Benton MO
County: Camden MO
County: Cass MO
County: Cedar MO
County: Dade MO
County: Dallas MO
County: Henry MO
County: Hickory MO
County: Jackson MO
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
168a
SC101805 Appeal Document Number 6 Page 66
HB 1
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
66
VTD: 412
VTD: 413
VTD: 414
VTD: 415
VTD: 616
VTD: 617
VTD: 618
VTD: 619
VTD: KC 1001
VTD: KC 1002
VTD: KC 1003
VTD: KC 1004
Block: 290950100021002
Block: 290950100021008
Block: 290950100021014
VTD KC 1004 Subtotal
VTD: KC 1005
VTD: KC 1006
VTD: KC 1007
VTD: KC 1008
Block: 290950100022004
Block: 290950100022008
Block: 290950100022011
VTD KC 1008 Subtotal
VTD: KC 1009
Block: 290950100022002
Block: 290950100022003
Block: 290950100023000
Block: 290950100023001
Block: 290950100023002
Block: 290950100023003
Block: 290950100023004
Block: 290950100023005
Block: 290950100023006
VTD KC 1009 Subtotal
VTD: KC 101
VTD: KC 1010
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
169a
SC101805 Appeal Document Number 6 Page 67
HB 1
50
51
52
53
54
55
56
57
58
59
60
61
62
63
64
65
66
67
68
69
70
71
72
73
74
75
76
77
78
79
80
81
82
83
84
85
86
67
VTD: KC 1011
VTD: KC 1012
VTD: KC 102
VTD: KC 103
VTD: KC 104
VTD: KC 105
VTD: KC 106
VTD: KC 107
VTD: KC 1101
Block: 290950003001011
Block: 290950003001012
Block: 290950003001013
Block: 290950003001014
Block: 290950003001017
Block: 290950003001018
Block: 290950003001019
Block: 290950003001020
Block: 290950003001022
Block: 290950003001024
Block: 290950003001025
Block: 290950003001026
Block: 290950003003016
Block: 290950003003020
Block: 290950003003021
Block: 290950003003022
Block: 290950003003024
Block: 290950003003025
VTD KC 1101 Subtotal
VTD: KC 1108
Block: 290950018002001
Block: 290950018002002
Block: 290950018002003
Block: 290950018002004
Block: 290950018002005
Block: 290950018002006
Block: 290950018002007
Block: 290950018002008
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
170a
SC101805 Appeal Document Number 6 Page 68
HB 1
87
88
89
90
91
92
93
94
95
96
97
98
99
100
101
102
103
104
105
106
107
108
109
110
111
112
113
114
115
116
117
118
119
120
121
122
123
68
Block: 290950018002009
Block: 290950018002010
Block: 290950018002011
VTD KC 1108 Subtotal
VTD: KC 1112
VTD: KC 1916
VTD: KC 1919
Block: 290950102031001
Block: 290950102031002
Block: 290950102031003
Block: 290950102031004
Block: 290950102031006
Block: 290950102031007
Block: 290950102031008
Block: 290950102031009
Block: 290950102031010
Block: 290950102031011
Block: 290950102031012
Block: 290950102031013
Block: 290950102031014
Block: 290950102031015
Block: 290950102031016
Block: 290950102031017
Block: 290950102031018
Block: 290950102031019
Block: 290950102031020
Block: 290950102031021
Block: 290950102031024
Block: 290950102034010
Block: 290950102034011
Block: 290950130032033
Block: 290950130032037
Block: 290950131003014
Block: 290950131003015
VTD KC 1919 Subtotal
VTD: KC 2001
Block: 290950131002011
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
171a
SC101805 Appeal Document Number 6 Page 69
HB 1
124
125
126
127
128
129
130
131
132
133
134
135
136
137
138
139
140
141
142
143
144
145
146
147
148
149
150
151
152
153
154
155
156
157
158
159
160
69
Block: 290950131002012
Block: 290950131002013
Block: 290950131002016
Block: 290950131002017
Block: 290950132082006
Block: 290950132082007
Block: 290950132082008
Block: 290950132082009
Block: 290950132082010
Block: 290950132082011
Block: 290950132082012
Block: 290950132082013
Block: 290950132082016
VTD KC 2001 Subtotal
VTD: KC 2002
VTD: KC 2003
VTD: KC 2004
Block: 290950102032000
Block: 290950102032001
Block: 290950102032002
Block: 290950102032003
Block: 290950102032004
Block: 290950102032005
Block: 290950102032006
Block: 290950102032007
Block: 290950102032008
Block: 290950102032009
Block: 290950102032010
Block: 290950102032011
Block: 290950102032012
Block: 290950102032013
Block: 290950102032014
Block: 290950102032015
Block: 290950102034000
VTD KC 2004 Subtotal
VTD: KC 2005
Block: 290950102032021
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
172a
SC101805 Appeal Document Number 6 Page 70
HB 1
161
162
163
164
165
166
167
168
169
170
171
172
173
174
175
176
177
178
179
180
181
182
183
184
185
186
187
188
189
190
191
192
193
194
195
196
197
70
Block: 290950102032022
Block: 290950102032023
Block: 290950102032024
Block: 290950102033001
Block: 290950102033002
Block: 290950102033003
Block: 290950102033004
Block: 290950102034001
Block: 290950102034002
Block: 290950102034004
Block: 290950102034006
Block: 290950102034007
Block: 290950102034008
Block: 290950102034009
VTD KC 2005 Subtotal
VTD: KC 2006
Block: 290950102033000
Block: 290950102034003
Block: 290950102034005
Block: 290950173001000
Block: 290950173001001
Block: 290950173001002
Block: 290950173001003
Block: 290950173001004
Block: 290950173001005
Block: 290950173001006
Block: 290950173001007
Block: 290950173001008
Block: 290950173001010
Block: 290950173001011
Block: 290950173001012
VTD KC 2006 Subtotal
VTD: KC 2007
VTD: KC 2008
VTD: KC 2009
VTD: KC 201
VTD: KC 2010
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
173a
SC101805 Appeal Document Number 6 Page 71
HB 1
198
199
200
201
202
203
204
205
206
207
208
209
210
211
212
213
214
215
216
217
218
219
220
221
222
223
224
225
226
227
228
229
230
231
232
233
234
71
VTD: KC 202
VTD: KC 203
Block: 290950154012001
Block: 290950154012002
Block: 290950154012003
Block: 290950154012004
Block: 290950154012013
Block: 290950154012014
Block: 290950154012015
Block: 290950154012016
Block: 290950154012017
Block: 290950154012020
Block: 290950154012021
Block: 290950154012022
Block: 290950154012023
Block: 290950154012024
VTD KC 203 Subtotal
VTD: KC 208
VTD: KC 212
Block: 290950043001000
Block: 290950043001001
Block: 290950043001007
Block: 290950043001009
Block: 290950043001010
Block: 290950043001019
Block: 290950043001020
Block: 290950043001021
Block: 290950154012037
Block: 290950154012058
Block: 290950158001000
Block: 290950158001027
Block: 290950158001029
Block: 290950158001030
Block: 290950158001064
Block: 290950158002026
Block: 290950159002028
Block: 290950159002029
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
174a
SC101805 Appeal Document Number 6 Page 72
HB 1
235
236
237
238
239
240
241
242
243
244
245
246
247
248
249
250
251
252
253
254
255
256
257
258
259
260
261
262
263
264
265
266
267
268
269
270
271
72
Block: 290950161001032
Block: 290950161002033
Block: 290950161002034
Block: 290950161002068
VTD KC 212 Subtotal
VTD: KC 217
Block: 290950154011015
Block: 290950154011016
Block: 290950154011026
Block: 290950154011027
Block: 290950154011028
Block: 290950154011029
Block: 290950154012006
Block: 290950154012007
Block: 290950154012008
Block: 290950154012009
Block: 290950154012010
Block: 290950154012011
Block: 290950154012026
Block: 290950154012027
Block: 290950154012028
Block: 290950154012029
Block: 290950154012036
Block: 290950154012038
VTD KC 217 Subtotal
VTD: KC 218
Block: 290950154011002
Block: 290950154011003
Block: 290950154011004
Block: 290950154011005
Block: 290950154011006
Block: 290950154011008
Block: 290950154011013
Block: 290950154011014
Block: 290950154011017
Block: 290950154011018
Block: 290950154011019
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
175a
SC101805 Appeal Document Number 6 Page 73
HB 1
272
273
274
275
276
277
278
279
280
281
282
283
284
285
286
287
288
289
290
291
292
293
294
295
296
297
298
299
300
301
302
303
304
305
306
307
308
73
Block: 290950154011020
Block: 290950154011024
Block: 290950154011025
Block: 290950154012005
Block: 290950154012012
Block: 290950154012025
VTD KC 218 Subtotal
VTD: KC 2201
VTD: KC 2202
VTD: KC 2203
VTD: KC 2204
VTD: KC 2205
VTD: KC 2206
VTD: KC 2207
VTD: KC 2208
VTD: KC 2209
VTD: KC 2210
VTD: KC 2211
VTD: KC 2212
VTD: KC 2213
VTD: KC 2502
VTD: KC 2503
Block: 290950136124000
Block: 290950136124002
Block: 290959883001007
Block: 290959883001011
Block: 290959883001012
Block: 290959883001013
Block: 290959883001014
Block: 290959883001015
Block: 290959883001016
Block: 290959883001017
VTD KC 2503 Subtotal
VTD: KC 2508
Block: 290950132082014
VTD KC 2508 Subtotal
VTD: KC 2510
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
176a
SC101805 Appeal Document Number 6 Page 74
HB 1
309
310
311
312
313
314
315
316
317
318
319
320
321
322
323
324
325
326
327
328
329
330
331
332
333
334
335
336
337
338
339
340
341
342
343
344
345
74
VTD: KC 2511
VTD: KC 2512
VTD: KC 401
VTD: KC 402
VTD: KC 403
VTD: KC 404
VTD: KC 405
VTD: KC 406
VTD: KC 407
VTD: KC 408
VTD: KC 409
VTD: KC 410
VTD: KC 411
VTD: KC 501
VTD: KC 502
VTD: KC 503
VTD: KC 504
VTD: KC 505
VTD: KC 506
VTD: KC 507
VTD: KC 508
VTD: KC 509
VTD: KC 510
VTD: KC 511
VTD: KC 512
VTD: KC 513
VTD: KC 601
VTD: KC 602
VTD: KC 603
VTD: KC 604
VTD: KC 605
VTD: KC 606
VTD: KC 607
VTD: KC 608
VTD: KC 609
VTD: KC 610
VTD: KC 611
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
177a
SC101805 Appeal Document Number 6 Page 75
HB 1
346
347
348
349
350
351
352
353
354
355
356
357
358
359
360
361
362
363
364
365
366
367
368
369
370
371
372
373
374
375
376
377
378
379
380
381
382
75
VTD: KC 612
VTD: KC 613
VTD: KC 614
VTD: KC 615
VTD: KC 801
VTD: KC 802
VTD: KC 803
VTD: KC 804
VTD: KC 805
VTD: KC 806
VTD: KC 807
VTD: KC 808
VTD: KC 809
Block: 290950086001004
Block: 290950086001005
Block: 290950086001006
Block: 290950086001007
Block: 290950086001008
Block: 290950086001009
Block: 290950086001011
Block: 290950086001013
Block: 290950086002006
Block: 290950086002007
Block: 290950086002008
Block: 290950086002009
Block: 290950086002010
Block: 290950086002011
Block: 290950086002012
Block: 290950086002013
Block: 290950086002014
Block: 290950086002015
Block: 290950086002016
Block: 290950086002017
Block: 290950086002018
Block: 290950086002019
Block: 290950086002020
Block: 290950086002021
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
178a
SC101805 Appeal Document Number 6 Page 76
HB 1
383
384
385
386
387
388
389
390
391
392
393
394
395
396
397
398
399
400
401
402
403
404
405
406
407
408
409
410
411
412
413
414
415
416
417
418
419
76
Block: 290950086002022
Block: 290950086002023
Block: 290950086002024
Block: 290950086002025
Block: 290950086002026
Block: 290950086002027
Block: 290950086002028
VTD KC 809 Subtotal
VTD: KC 811
VTD: KC 812
VTD: KC 813
VTD: KC 814
VTD: KC 815
VTD: KC 901
VTD: KC 902
VTD: KC 903
VTD: KC 904
VTD: KC 906
VTD: KC 907
VTD: KC 908
VTD: KC 909
VTD: KC 910
VTD: KC 911
VTD: KC WD2 PCT211
Block: 290950018003000
Block: 290950018003001
Block: 290950018003002
Block: 290950018003003
Block: 290950018003004
Block: 290950018003005
Block: 290950018003006
Block: 290950018003007
Block: 290950018003008
Block: 290950018003009
Block: 290950018003010
Block: 290950018003011
Block: 290950018003012
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
179a
SC101805 Appeal Document Number 6 Page 77
HB 1
420
421
422
423
424
425
426
427
428
429
430
431
432
433
434
435
436
437
438
439
440
441
442
443
444
445
446
447
448
449
450
451
452
453
454
455
456
77
Block: 290950018003013
Block: 290950018003014
Block: 290950018003015
Block: 290950018003016
Block: 290950018003017
Block: 290950018003018
Block: 290950018003019
Block: 290950018004004
VTD KC WD2 PCT211 Subtotal
VTD: KC WD8 PCT810
VTD: Prairie 03
VTD: Prairie 04
VTD: Prairie 05
VTD: Prairie 06
VTD: Prairie 07
VTD: Prairie 08
VTD: Prairie 09
VTD: Prairie 11
VTD: Prairie 12
VTD: Prairie 13
VTD: Prairie 14
VTD: Prairie 15
VTD: Prairie 16
VTD: Prairie 17
VTD: Prairie 18
VTD: Prairie 19
VTD: Prairie 20
VTD: Prairie 21
VTD: Prairie 22
VTD: Prairie 23
VTD: Prairie 24
VTD: Prairie 26
VTD: Prairie 27
Block: 290950142031000
Block: 290950142031001
Block: 290950142031002
Block: 290950142031003
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
180a
SC101805 Appeal Document Number 6 Page 78
HB 1
457
458
459
460
461
462
463
464
465
466
467
468
469
470
471
472
473
474
475
476
477
478
479
480
481
482
483
484
485
486
487
488
489
490
491
492
493
78
Block: 290950142031015
Block: 290950142031016
Block: 290950142031017
Block: 290950142031019
Block: 290950142031020
Block: 290950142031021
Block: 290950142032000
Block: 290950142032001
Block: 290950142032002
Block: 290950142032003
Block: 290950142032004
Block: 290950142032005
Block: 290950142032006
Block: 290950142033000
Block: 290950142033001
Block: 290950142033002
Block: 290950142033003
Block: 290950142033004
Block: 290950142033005
Block: 290950142033006
Block: 290950142033007
Block: 290950185003005
Block: 290950185003007
VTD Prairie 27 Subtotal
VTD: Prairie 28
VTD: Prairie 29
Block: 290950142061000
Block: 290950185002000
Block: 290950185002001
Block: 290950185002002
Block: 290950185002006
Block: 290950185003006
Block: 290950185003008
Block: 290950185003009
Block: 290950185003010
Block: 290950185003011
Block: 290950185003012
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
181a
SC101805 Appeal Document Number 6 Page 79
HB 1
494
495
496
497
498
499
500
501
502
503
504
505
506
507
508
509
510
511
512
513
514
515
516
517
518
519
520
521
522
523
524
525
526
527
528
529
530
79
Block: 290950185003013
Block: 290950185003014
Block: 290950185003015
Block: 290950185003016
Block: 290950185003017
Block: 290950185003018
Block: 290950193022015
Block: 290950193022016
Block: 290959891001001
Block: 290959891001002
Block: 290959891001003
Block: 290959891001011
VTD Prairie 29 Subtotal
VTD: Prairie 30
VTD: Prairie 31
VTD: Prairie 32
VTD: Prairie 33
VTD: Prairie 34
VTD: Prairie 35
VTD: Prairie 36
VTD: Prairie 37
VTD: Prairie 38
VTD: Prairie 39
VTD: Prairie 40
VTD: Prairie 41
VTD: Prairie 42
VTD: Prairie 43
VTD: Prairie 44
VTD: Prairie 45
VTD: Prairie 46
VTD: Prairie 47
VTD: Prairie 48
VTD: Prairie 49
VTD: Prairie 50
VTD: Prairie 51
VTD: Prairie 52
VTD: Prairie 56
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
182a
SC101805 Appeal Document Number 6 Page 80
HB 1
531
532
533
534
535
536
537
538
539
540
541
542
543
544
545
546
547
548
549
550
551
552
553
554
555
556
557
558
559
560
561
562
563
564
565
566
567
80
VTD: Prairie 59
VTD: Prairie 60
VTD: Prairie 62
VTD: Prarie 02
VTD: Prarie 10
VTD: Prarie 25
VTD: Prarie 53
VTD: Prarie 54
VTD: Prarie 55
VTD: Prarie 57
VTD: Prarie 58
VTD: Prarie 61
VTD: Prarie 63
VTD: Sni-A-Bar 02
Block: 290950193022001
Block: 290950193022003
Block: 290950193022004
Block: 290950193022005
VTD Sni-A-Bar 02 Subtotal
VTD: Sni-A-Bar 03
Block: 290950193022017
VTD Sni-A-Bar 03 Subtotal
VTD: Sni-A-Bar 07
Block: 290950148061000
Block: 290950148061001
Block: 290950149041002
Block: 290950149041003
Block: 290950149041005
Block: 290950149041006
Block: 290950149041007
Block: 290950149041008
Block: 290950149041009
Block: 290950149041013
Block: 290950149041014
Block: 290950149041015
Block: 290950149041017
Block: 290950149041018
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
183a
SC101805 Appeal Document Number 6 Page 81
HB 1
568
569
570
571
572
573
574
575
576
577
578
579
580
581
582
583
584
585
586
587
588
589
590
591
592
593
594
595
596
597
598
599
600
601
602
603
604
81
Block: 290950149041019
Block: 290950149041020
Block: 290950149041021
Block: 290950149041022
Block: 290950149041028
Block: 290950149041029
Block: 290950149041030
Block: 290950149041031
VTD Sni-A-Bar 07 Subtotal
VTD: Sni-A-Bar 08
Block: 290950148061015
Block: 290950148061016
Block: 290950148061017
Block: 290950148061018
Block: 290950148062000
Block: 290950148062001
Block: 290950148062002
Block: 290950148062003
Block: 290950148062004
Block: 290950148062005
Block: 290950148062006
Block: 290950148062007
Block: 290950148062008
Block: 290950148062009
Block: 290950148062010
Block: 290950148062011
Block: 290950148062012
Block: 290950148062013
Block: 290950148062014
Block: 290950148062015
Block: 290950148063000
Block: 290950148063001
Block: 290950148063002
Block: 290950148063003
Block: 290950148063004
Block: 290950148063005
Block: 290950148063006
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
184a
SC101805 Appeal Document Number 6 Page 82
HB 1
605
606
607
608
609
610
611
612
613
614
615
616
617
618
619
620
621
622
623
624
625
626
627
628
629
630
631
632
633
634
635
636
637
638
639
640
641
82
Block: 290950148063007
Block: 290950148063008
Block: 290950148063009
Block: 290950148063010
Block: 290959892001002
Block: 290959892001003
Block: 290959892001004
Block: 290959892001005
VTD Sni-A-Bar 08 Subtotal
VTD: Sni-A-Bar 09
VTD: Sni-A-Bar 10
VTD: Sni-A-Bar 11
VTD: Sni-A-Bar 12
VTD: Sni-A-Bar 13
VTD: Sni-A-Bar 14
Block: 290950149051001
Block: 290950149051016
Block: 290950149051017
Block: 290950149051018
Block: 290950149051019
Block: 290950149051020
Block: 290950149051021
Block: 290950149051022
Block: 290950149051025
Block: 290950149052003
Block: 290950149052016
Block: 290950149052017
Block: 290950149052018
Block: 290950149052019
Block: 290950149052020
Block: 290950149052021
Block: 290950149052022
Block: 290950149052025
Block: 290950149052029
Block: 290950149052030
Block: 290950149052031
Block: 290950149052032
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
185a
SC101805 Appeal Document Number 6 Page 83
HB 1
642
643
644
645
646
647
648
649
650
651
652
653
654
655
656
657
658
659
660
661
662
663
664
665
666
667
668
669
670
671
672
673
674
675
676
677
678
83
Block: 290950149052033
VTD Sni-A-Bar 14 Subtotal
VTD: Sni-A-Bar 15
VTD: Sni-A-Bar 16
Block: 290950141221006
Block: 290950141221007
Block: 290950141281001
Block: 290950141281002
Block: 290950141281003
Block: 290950141281004
Block: 290950141281005
Block: 290950141281008
Block: 290950141281009
Block: 290950141281010
Block: 290950141281017
Block: 290950141281018
Block: 290950141281019
Block: 290950141281020
Block: 290950141281024
Block: 290950141281025
Block: 290950141283000
VTD Sni-A-Bar 16 Subtotal
VTD: Sni-A-Bar 17
VTD: Sni-A-Bar 18
VTD: Sni-A-Bar 19
VTD: Sni-A-Bar 20
VTD: Sni-A-Bar 21
VTD: Sni-A-Bar 22
VTD: Sni-A-Bar 23
VTD: Sni-A-Bar 24
VTD: Sni-A-Bar 25
VTD: Sni-A-Bar 26
VTD: Sni-A-Bar 27
VTD: Sni-A-Bar 28
VTD: Sni-A-Bar 29
VTD: Sni-A-Bar 30
VTD: Sni-A-Bar 31
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
186a
SC101805 Appeal Document Number 6 Page 84
HB 1
679
680
681
682
683
684
685
686
687
688
689
690
691
692
693
694
695
696
697
698
699
700
701
702
703
704
705
706
707
708
709
710
711
712
713
714
715
84
VTD: Sni-A-Bar 32
VTD: Sni-A-Bar 33
VTD: Sni-A-Bar 34
VTD: Sni-A-Bar 35
VTD: Sni-A-Bar 36
VTD: Sni-A-Bar 37
Block: 290950140021009
Block: 290950140021011
Block: 290950140021014
Block: 290950140021015
Block: 290950140021026
Block: 290950140021027
Block: 290950140021028
Block: 290950140021029
Block: 290950140021030
Block: 290950140021031
Block: 290950140021032
Block: 290950140021035
Block: 290950140021036
Block: 290950140022006
Block: 290950140022007
Block: 290950140022008
Block: 290950140022009
Block: 290950140022010
Block: 290950140022011
Block: 290950140022012
Block: 290950140022013
Block: 290950140022016
Block: 290950140022017
Block: 290950140022018
Block: 290950140022040
Block: 290950140022041
Block: 290950140051019
Block: 290950140063021
Block: 290950140063022
Block: 290950140063023
Block: 290950140063024
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
187a
SC101805 Appeal Document Number 6 Page 85
HB 1
716
717
718
719
720
721
722
723
724
725
726
727
728
729
730
731
732
733
734
735
736
737
738
739
740
741
742
743
744
745
746
747
748
749
750
751
752
85
Block: 290950140063025
Block: 290950141112001
Block: 290950141112007
Block: 290950141112008
Block: 290950141121000
Block: 290950141121001
Block: 290950141121002
Block: 290950141121003
Block: 290950141121004
Block: 290950141121015
VTD Sni-A-Bar 37 Subtotal
VTD: Sni-A-Bar 41
Block: 290950141281000
VTD Sni-A-Bar 41 Subtotal
VTD: Sni-A-Bar 45
Block: 290950140021019
Block: 290950140021020
Block: 290950140021022
Block: 290950140021023
Block: 290950140021024
Block: 290950140021025
Block: 290950140021033
Block: 290950140021034
Block: 290950140022003
Block: 290950140022004
Block: 290950140022005
Block: 290950140022024
Block: 290950140051035
Block: 290950140051036
Block: 290950140051037
Block: 290950140051039
Block: 290950140051040
Block: 290950140051041
Block: 290950140051042
Block: 290950140054015
Block: 290950140054016
Block: 290950140054018
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
188a
SC101805 Appeal Document Number 6 Page 86
HB 1
753
754
755
756
757
758
759
760
761
762
763
764
765
766
767
768
769
770
771
772
773
774
775
776
777
778
779
780
781
782
783
784
785
786
787
788
789
86
VTD Sni-A-Bar 45 Subtotal
VTD: Sni-A-Bar 83
VTD: Van Buren 01
VTD: Van Buren 02
VTD: Van Buren 03
VTD: Van Buren 04
VTD: Van Buren 06
VTD: Van Buren 07
VTD: Van Buren 08
VTD: Van Buren 09
VTD: Van Buren 10
VTD: Van Buren 11
VTD: Van Buren 12
VTD: Van Buren 13
VTD: Van Buren 14
VTD: Van Buren 15
VTD: Van Buren 16
VTD: Van Buren 17
VTD: Van Buren 18
VTD: Van Buren 19
VTD: Washington 01
VTD: Washington 02
VTD: Washington 03
VTD: Washington 04
VTD: Washington 05
VTD: Washington 06
VTD: Washington 07
VTD: Washington 08
VTD: Washington 09
VTD: Washington 10
VTD: Washington 11
VTD: Washington 12
County Jackson MO Subtotal
County: Laclede MO
County: Polk MO
County: Pulaski MO
County: St. Clair MO
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
189a
SC101805 Appeal Document Number 6 Page 87
HB 1
790
791
792
793
794
795
796
797
798
799
800
801
802
803
804
805
806
807
808
809
810
811
812
813
814
815
816
817
818
819
820
821
822
823
824
825
826
87
County: Vernon MO
County: Webster MO
VTD: East Ozark
VTD: Grant
Block: 292254701021041
Block: 292254701021042
Block: 292254701022000
Block: 292254701022001
Block: 292254701022002
Block: 292254701022003
Block: 292254701022004
Block: 292254701022005
Block: 292254701022006
Block: 292254701022007
Block: 292254701022008
Block: 292254701022009
Block: 292254701022010
Block: 292254701022011
Block: 292254701022012
Block: 292254701022013
Block: 292254701022014
Block: 292254701022015
Block: 292254701022019
Block: 292254701022020
Block: 292254701022021
Block: 292254701022022
Block: 292254701022023
Block: 292254701022024
Block: 292254701022025
Block: 292254701022026
Block: 292254701022027
Block: 292254701022028
Block: 292254701022029
Block: 292254701022030
Block: 292254701022031
Block: 292254701022032
Block: 292254701022033
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
190a
SC101805 Appeal Document Number 6 Page 88
HB 1
827
828
829
830
831
832
833
834
835
836
837
838
839
840
841
842
843
844
845
846
847
848
849
850
851
852
853
854
855
856
857
858
859
860
861
862
863
88
Block: 292254701022034
Block: 292254701022035
Block: 292254701022036
Block: 292254701022037
Block: 292254701022038
Block: 292254701022039
Block: 292254701022040
Block: 292254701022041
Block: 292254701022042
Block: 292254701022043
Block: 292254701022044
Block: 292254701022045
Block: 292254701022046
Block: 292254701022047
Block: 292254701022048
Block: 292254701022049
Block: 292254701022050
Block: 292254701022051
Block: 292254701022052
Block: 292254701022053
Block: 292254701022054
Block: 292254701022055
Block: 292254701022056
Block: 292254701022057
Block: 292254701022058
Block: 292254701022059
Block: 292254701022061
Block: 292254701023081
Block: 292254701023082
Block: 292254701023085
Block: 292254701023086
VTD Grant Subtotal
VTD: High Prairie
VTD: Jackson
VTD: Marshfield East
VTD: Marshfield West
VTD: Niangua
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
191a
SC101805 Appeal Document Number 6 Page 89
HB 1
864
865
866
867
868
869
870
871
872
873
874
875
876
877
878
879
880
881
882
883
884
885
886
887
888
889
890
891
892
893
894
895
896
897
898
899
900
89
VTD: Northview A
VTD: Northview B
Block: 292254702022011
Block: 292254702022012
Block: 292254702022013
Block: 292254702022016
Block: 292254702022019
Block: 292254702022020
Block: 292254702022021
Block: 292254702022022
Block: 292254702022023
Block: 292254702022024
Block: 292254702022025
Block: 292254702022037
Block: 292254702022038
Block: 292254702022039
Block: 292254702022040
Block: 292254703022009
Block: 292254703022011
Block: 292254703023000
Block: 292254703023001
Block: 292254703023002
Block: 292254703023003
Block: 292254703023004
Block: 292254703023005
Block: 292254703023006
Block: 292254703023014
Block: 292254703023015
Block: 292254703023016
Block: 292254703023017
Block: 292254703023018
Block: 292254703023019
Block: 292254703023020
Block: 292254703023021
Block: 292254703023022
Block: 292254703023023
Block: 292254703023024
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
192a
SC101805 Appeal Document Number 6 Page 90
HB 1
901
902
903
904
905
906
907
908
909
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
90
Block: 292254703023025
Block: 292254703023026
Block: 292254703023027
Block: 292254703023034
VTD Northview B Subtotal
VTD: Union
VTD: Washington
County Webster MO Subtotal
District 4 Total
128.475. The fifth congressional district shall be composed of the following:
County: Boone MO
VTD: 07
VTD: 08
VTD: 09
VTD: 10
VTD: 11
VTD: 12
VTD: 15
VTD: 16
VTD: 17
Block: 290190015031004
Block: 290190015031013
Block: 290190015062000
Block: 290190015062001
Block: 290190015062002
Block: 290190015062003
Block: 290190015062004
Block: 290190015062006
Block: 290190015062007
Block: 290190015062012
Block: 290190015062018
Block: 290190015062019
Block: 290190015062021
Block: 290190016031001
Block: 290190016031005
Block: 290190016031006
Block: 290190016031007
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
193a
SC101805 Appeal Document Number 6 Page 91
HB 1
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
59
60
61
62
63
64
65
91
Block: 290190016031012
Block: 290190016031017
Block: 290190019031003
Block: 290190019031004
Block: 290190019031005
Block: 290190019031006
Block: 290190019031007
Block: 290190019031008
Block: 290190019031009
Block: 290190019031010
Block: 290190019031011
Block: 290190019031012
Block: 290190019031013
Block: 290190019031014
Block: 290190019031015
Block: 290190019031016
Block: 290190019031017
Block: 290190019031018
Block: 290190019031019
Block: 290190019031020
Block: 290190019031021
Block: 290190019031022
Block: 290190019031023
Block: 290190019031024
Block: 290190019032037
Block: 290190019032038
Block: 290190019032044
Block: 290190019032045
Block: 290190019032046
Block: 290190019032047
Block: 290190019032049
Block: 290190019033053
Block: 290190019033054
Block: 290190019033055
Block: 290190019033056
Block: 290190019033057
Block: 290190019033059
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
194a
SC101805 Appeal Document Number 6 Page 92
HB 1
66
67
68
69
70
71
72
73
74
75
76
77
78
79
80
81
82
83
84
85
86
87
88
89
90
91
92
93
94
95
96
97
98
99
100
101
102
92
Block: 290190019033060
VTD 17 Subtotal
VTD: 18
VTD: 19
VTD: 20
Block: 290190014013030
Block: 290190014013031
Block: 290190014013032
Block: 290190014013048
Block: 290190014013051
Block: 290190014024000
Block: 290190014024004
Block: 290190014024005
Block: 290190014024006
Block: 290190014024007
Block: 290190014024008
Block: 290190014024011
Block: 290190014024012
Block: 290190018031003
Block: 290190018031004
Block: 290190018031005
Block: 290190018031006
Block: 290190018031007
Block: 290190018031008
Block: 290190018031010
Block: 290190018031011
Block: 290190018031019
Block: 290190018031020
Block: 290190018031021
Block: 290190018031022
Block: 290190018031023
Block: 290190018031024
Block: 290190018031025
Block: 290190018031026
Block: 290190018031027
Block: 290190018031028
Block: 290190018032000
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
195a
SC101805 Appeal Document Number 6 Page 93
HB 1
103
104
105
106
107
108
109
110
111
112
113
114
115
116
117
118
119
120
121
122
123
124
125
126
127
128
129
130
131
132
133
134
135
136
137
138
139
93
Block: 290190018032001
Block: 290190018032007
Block: 290190019012028
Block: 290190019012029
Block: 290190019012030
Block: 290190019012031
Block: 290190019012032
Block: 290190019012037
Block: 290190019012038
Block: 290190019012046
Block: 290190019012047
Block: 290190019012049
Block: 290190019012051
Block: 290190019013050
VTD 20 Subtotal
VTD: 21
Block: 290190013003003
Block: 290190013003004
Block: 290190018061007
Block: 290190018071011
Block: 290190018071012
Block: 290190018071013
Block: 290190018071014
Block: 290190018071015
Block: 290190018071016
Block: 290190018071022
Block: 290190018071023
Block: 290190018071024
Block: 290190018071025
Block: 290190018071026
Block: 290190018071027
Block: 290190018071028
Block: 290190018072000
Block: 290190018072012
Block: 290190018072014
Block: 290190018072017
Block: 290190018072018
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
196a
SC101805 Appeal Document Number 6 Page 94
HB 1
140
141
142
143
144
145
146
147
148
149
150
151
152
153
154
155
156
157
158
159
160
161
162
163
164
165
166
167
168
169
170
171
172
173
174
175
176
94
Block: 290190018072022
Block: 290190018072023
VTD 21 Subtotal
VTD: 22
Block: 290190014012004
Block: 290190014012005
Block: 290190014012006
Block: 290190014012007
Block: 290190014012008
Block: 290190014012009
Block: 290190014012010
Block: 290190014012011
Block: 290190014012012
Block: 290190014012013
Block: 290190014012015
Block: 290190014012016
Block: 290190014012019
Block: 290190014012020
Block: 290190014012021
Block: 290190014012027
Block: 290190014012028
Block: 290190014012031
Block: 290190014013000
Block: 290190014013001
Block: 290190014013002
Block: 290190014013003
Block: 290190014013004
Block: 290190014013005
Block: 290190014013006
Block: 290190014013012
Block: 290190014013017
Block: 290190014013025
Block: 290190014013026
Block: 290190014013027
Block: 290190014013028
Block: 290190014013029
Block: 290190014013033
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
197a
SC101805 Appeal Document Number 6 Page 95
HB 1
177
178
179
180
181
182
183
184
185
186
187
188
189
190
191
192
193
194
195
196
197
198
199
200
201
202
203
204
205
206
207
208
209
210
211
212
213
95
Block: 290190014013055
Block: 290190018031012
Block: 290190018031013
Block: 290190018031014
Block: 290190018031029
Block: 290190018031030
VTD 22 Subtotal
VTD: 2I
Block: 290190014013053
VTD 2I Subtotal
VTD: 2K
Block: 290190018072001
Block: 290190018072002
Block: 290190018072003
Block: 290190018072004
Block: 290190018072005
Block: 290190018072006
Block: 290190018072007
Block: 290190018072008
Block: 290190018072010
VTD 2K Subtotal
VTD: 37
Block: 290190017021039
Block: 290190017021040
Block: 290190018062032
Block: 290190018062034
Block: 290190018062039
Block: 290190018062040
Block: 290190018062041
Block: 290190018062042
Block: 290190018062043
Block: 290190018062045
VTD 37 Subtotal
VTD: 38
VTD: 39
VTD: 3A
Block: 290190015062030
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
198a
SC101805 Appeal Document Number 6 Page 96
HB 1
214
215
216
217
218
219
220
221
222
223
224
225
226
227
228
229
230
231
232
233
234
235
236
237
238
239
240
241
242
243
244
245
246
247
248
249
250
96
VTD 3A Subtotal
VTD: 3B
Block: 290190015062017
VTD 3B Subtotal
VTD: 40
Block: 290190015031005
Block: 290190015031006
Block: 290190015031007
Block: 290190015031008
Block: 290190015031009
Block: 290190015031021
Block: 290190015031022
Block: 290190015031026
Block: 290190015033000
Block: 290190015033001
Block: 290190015033002
Block: 290190015033003
Block: 290190015033004
Block: 290190015033005
Block: 290190015033009
Block: 290190015033010
Block: 290190015033011
Block: 290190015033013
Block: 290190015033015
Block: 290190015033017
Block: 290190015033018
Block: 290190015033019
Block: 290190015033020
Block: 290190015033021
Block: 290190015033023
Block: 290190015033024
Block: 290190015033031
Block: 290190015033053
Block: 290190015033054
Block: 290190015033055
Block: 290190019032050
Block: 290190019032051
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
199a
SC101805 Appeal Document Number 6 Page 97
HB 1
251
252
253
254
255
256
257
258
259
260
261
262
263
264
265
266
267
268
269
270
271
272
273
274
275
276
277
278
279
280
281
282
283
284
285
286
287
97
Block: 290190019032054
VTD 40 Subtotal
VTD: 45
Block: 290190015031023
Block: 290190015031024
Block: 290190015031025
Block: 290190015031027
Block: 290190015031028
Block: 290190015031029
Block: 290190015031030
Block: 290190015031031
Block: 290190015032015
Block: 290190015033027
Block: 290190015033029
Block: 290190015033032
Block: 290190015033049
Block: 290190015033050
Block: 290190015033051
Block: 290190015033056
Block: 290190015033057
Block: 290190015033058
Block: 290190015081000
Block: 290190015081001
VTD 45 Subtotal
VTD: 4B
Block: 290190018071000
Block: 290190018071001
Block: 290190018071002
Block: 290190018071003
Block: 290190018071004
Block: 290190018071005
Block: 290190018071006
Block: 290190018071007
Block: 290190018071008
Block: 290190018071009
Block: 290190018071010
Block: 290190018072009
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
200a
SC101805 Appeal Document Number 6 Page 98
HB 1
288
289
290
291
292
293
294
295
296
297
298
299
300
301
302
303
304
305
306
307
308
309
310
311
312
313
314
315
316
317
318
319
320
321
322
323
324
98
Block: 290190018072011
Block: 290190018072013
Block: 290190018072016
Block: 290190018072019
Block: 290190018072020
Block: 290190018072021
Block: 290190018072026
VTD 4B Subtotal
VTD: 4K
Block: 290190018072027
VTD 4K Subtotal
VTD: 4L
Block: 290190018072015
VTD 4L Subtotal
County Boone MO Subtotal
County: Cole MO
County: Cooper MO
County: Howard MO
County: Jackson MO
VTD: 1603
VTD: Blue 01-01
VTD: Blue 01-02
VTD: Blue 01-03
VTD: Blue 01-04
VTD: Blue 01-05
VTD: Blue 01-06
VTD: Blue 01-07
VTD: Blue 01-08
VTD: Blue 01-09
VTD: Blue 02-01
VTD: Blue 02-02
VTD: Blue 02-03
VTD: Blue 02-04
VTD: Blue 02-05
VTD: Blue 02-06
VTD: Blue 02-07
VTD: Blue 03-01
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
201a
SC101805 Appeal Document Number 6 Page 99
HB 1
325
326
327
328
329
330
331
332
333
334
335
336
337
338
339
340
341
342
343
344
345
346
347
348
349
350
351
352
353
354
355
356
357
358
359
360
361
99
VTD: Blue 03-02
VTD: Blue 03-03
VTD: Blue 03-04
VTD: Blue 03-05
VTD: Blue 03-06
VTD: Blue 03-07
VTD: Blue 03-08
VTD: Blue 03-09
VTD: Blue 04-01
VTD: Blue 04-02
VTD: Blue 04-03
VTD: Blue 04-04
VTD: Blue 04-05
VTD: Blue 04-06
VTD: Blue 04-07
VTD: Blue 04-08
VTD: Blue 04-09
VTD: Blue 04-10
VTD: Blue 05-01
VTD: Blue 05-02
VTD: Blue 05-03
VTD: Blue 05-04
VTD: Blue 05-05
VTD: Blue 05-06
VTD: Blue 05-07
VTD: Blue 05-08
VTD: Blue 05-09
VTD: Blue 06-01
VTD: Blue 06-02
VTD: Blue 06-03
VTD: Blue 06-04
VTD: Blue 06-05
VTD: Blue 06-06
VTD: Blue 06-07
VTD: Blue 07-01
VTD: Blue 07-02
VTD: Blue 07-03
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
202a
SC101805 Appeal Document Number 6 Page 100
HB 1
362
363
364
365
366
367
368
369
370
371
372
373
374
375
376
377
378
379
380
381
382
383
384
385
386
387
388
389
390
391
392
393
394
395
396
397
398
100
VTD: Blue 07-04
VTD: Blue 07-05
VTD: Blue 07-06
VTD: Blue 07-07
VTD: Blue 07-08
VTD: Blue 07-09
VTD: Blue 08-01
VTD: Blue 08-02
VTD: Blue 08-03
VTD: Blue 08-04
VTD: Blue 08-05
VTD: Blue 08-06
VTD: Blue 08-07
VTD: Blue 08-08
VTD: Brooking No. 1
VTD: Brooking No. 10
VTD: Brooking No. 11
VTD: Brooking No. 12
VTD: Brooking No. 13
VTD: Brooking No. 14
VTD: Brooking No. 15
VTD: Brooking No. 16
VTD: Brooking No. 17
VTD: Brooking No. 18
VTD: Brooking No. 19
VTD: Brooking No. 2
VTD: Brooking No. 20
VTD: Brooking No. 3
VTD: Brooking No. 4
VTD: Brooking No. 5
VTD: Brooking No. 6
VTD: Brooking No. 7
VTD: Brooking No. 8
VTD: Brooking No. 9
VTD: Fort Osage 01
VTD: Fort Osage 02
VTD: Fort Osage 03
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
203a
SC101805 Appeal Document Number 6 Page 101
HB 1
399
400
401
402
403
404
405
406
407
408
409
410
411
412
413
414
415
416
417
418
419
420
421
422
423
424
425
426
427
428
429
430
431
432
433
434
435
101
VTD: Fort Osage 04
VTD: Fort Osage 05
VTD: Fort Osage 06
VTD: Fort Osage 07
VTD: Fort Osage 08
VTD: Fort Osage 09
VTD: Fort Osage 10
VTD: KC 1004
Block: 290950100021000
Block: 290950100021001
Block: 290950100021009
Block: 290950100021010
Block: 290950100021011
VTD KC 1004 Subtotal
VTD: KC 1008
Block: 290950100022005
Block: 290950100022006
Block: 290950100022007
Block: 290950100022009
Block: 290950100022010
VTD KC 1008 Subtotal
VTD: KC 1009
Block: 290950100022000
Block: 290950100022001
VTD KC 1009 Subtotal
VTD: KC 1108
Block: 290950018002000
VTD KC 1108 Subtotal
VTD: KC 1201
Block: 290950007003001
Block: 290950007003002
Block: 290950007003003
Block: 290950007003004
Block: 290950007003007
Block: 290950007003008
Block: 290950008002000
Block: 290950008002001
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
204a
SC101805 Appeal Document Number 6 Page 102
HB 1
436
437
438
439
440
441
442
443
444
445
446
447
448
449
450
451
452
453
454
455
456
457
458
459
460
461
462
463
464
465
466
467
468
469
470
471
472
102
VTD KC 1201 Subtotal
VTD: KC 1205
VTD: KC 1206
VTD: KC 1207
VTD: KC 1208
VTD: KC 1209
VTD: KC 1210
VTD: KC 1211
VTD: KC 1212
VTD: KC 1301
VTD: KC 1303
VTD: KC 1304
VTD: KC 1305
VTD: KC 1306
VTD: KC 1307
VTD: KC 1308
VTD: KC 1309
VTD: KC 1310
VTD: KC 1311
VTD: KC 1313
VTD: KC 1401
VTD: KC 1402
VTD: KC 1403
VTD: KC 1404
VTD: KC 1405
VTD: KC 1406
VTD: KC 1407
VTD: KC 1408
VTD: KC 1409
VTD: KC 1410
VTD: KC 1411
VTD: KC 1412
VTD: KC 1413
VTD: KC 1414
VTD: KC 1415
VTD: KC 1501
VTD: KC 1502
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
205a
SC101805 Appeal Document Number 6 Page 103
HB 1
473
474
475
476
477
478
479
480
481
482
483
484
485
486
487
488
489
490
491
492
493
494
495
496
497
498
499
500
501
502
503
504
505
506
507
508
509
103
VTD: KC 1503
VTD: KC 1504
VTD: KC 1505
VTD: KC 1506
VTD: KC 1507
VTD: KC 1508
VTD: KC 1509
VTD: KC 1510
VTD: KC 1511
VTD: KC 1512
VTD: KC 1513
VTD: KC 1514
VTD: KC 1515
VTD: KC 1516
VTD: KC 1517
VTD: KC 1518
VTD: KC 1519
VTD: KC 1520
VTD: KC 1521
VTD: KC 1522
VTD: KC 1523
VTD: KC 1524
VTD: KC 1601
VTD: KC 1602
VTD: KC 1604
VTD: KC 1605
VTD: KC 1606
VTD: KC 1607
VTD: KC 1608
VTD: KC 1609
VTD: KC 1610
VTD: KC 1611
VTD: KC 1612
VTD: KC 1613
VTD: KC 1614
VTD: KC 1615
VTD: KC 1701
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
206a
SC101805 Appeal Document Number 6 Page 104
HB 1
510
511
512
513
514
515
516
517
518
519
520
521
522
523
524
525
526
527
528
529
530
531
532
533
534
535
536
537
538
539
540
541
542
543
544
545
546
104
VTD: KC 1702
VTD: KC 1703
VTD: KC 1704
VTD: KC 1705
VTD: KC 1706
VTD: KC 1707
VTD: KC 1708
VTD: KC 1709
VTD: KC 1710
VTD: KC 1711
VTD: KC 1712
VTD: KC 1713
VTD: KC 1714
VTD: KC 1801
VTD: KC 1802
VTD: KC 1803
VTD: KC 1804
VTD: KC 1805
VTD: KC 1806
VTD: KC 1807
VTD: KC 1808
VTD: KC 1809
VTD: KC 1810
VTD: KC 1811
VTD: KC 1812
VTD: KC 1813
VTD: KC 1814
VTD: KC 1815
VTD: KC 1816
VTD: KC 1901
VTD: KC 1902
VTD: KC 1903
VTD: KC 1904
VTD: KC 1905
VTD: KC 1906
VTD: KC 1907
VTD: KC 1908
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
207a
SC101805 Appeal Document Number 6 Page 105
HB 1
547
548
549
550
551
552
553
554
555
556
557
558
559
560
561
562
563
564
565
566
567
568
569
570
571
572
573
574
575
576
577
578
579
580
581
582
583
105
VTD: KC 1909
VTD: KC 1910
VTD: KC 1911
VTD: KC 1912
VTD: KC 1913
VTD: KC 1914
VTD: KC 1915
VTD: KC 1917
VTD: KC 1918
VTD: KC 1919
Block: 290950102011013
Block: 290950130032034
VTD KC 1919 Subtotal
VTD: KC 1920
VTD: KC 1921
VTD: KC 1922
VTD: KC 1923
VTD: KC 2001
Block: 290950132082004
Block: 290950132082005
VTD KC 2001 Subtotal
VTD: KC 2004
Block: 290950102011012
VTD KC 2004 Subtotal
VTD: KC 2005
Block: 290950102011011
VTD KC 2005 Subtotal
VTD: KC 2006
Block: 290950101031016
Block: 290950101032004
Block: 290950101032005
Block: 290950101033007
VTD KC 2006 Subtotal
VTD: KC 203
Block: 290950154012030
Block: 290950154012031
Block: 290950154012032
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
208a
SC101805 Appeal Document Number 6 Page 106
HB 1
584
585
586
587
588
589
590
591
592
593
594
595
596
597
598
599
600
601
602
603
604
605
606
607
608
609
610
611
612
613
614
615
616
617
618
619
620
106
Block: 290950154012033
Block: 290950154012034
Block: 290950154012039
Block: 290950154012040
Block: 290950154012041
Block: 290950154012042
Block: 290950154012046
Block: 290950154012047
Block: 290950154012054
Block: 290950154012055
Block: 290950154012056
Block: 290950154012057
Block: 290950154013011
Block: 290950154013012
Block: 290950154013013
Block: 290950154013014
Block: 290950154013015
Block: 290950161002000
Block: 290950161002001
Block: 290950161002002
Block: 290950161002003
Block: 290950161002004
Block: 290950161002005
Block: 290950161002006
Block: 290950161002007
Block: 290950161002008
Block: 290950161002009
Block: 290950161002010
Block: 290950161002011
Block: 290950161002012
Block: 290950161002013
Block: 290950161002014
Block: 290950161002015
Block: 290950161002016
Block: 290950161002017
VTD KC 203 Subtotal
VTD: KC 204
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
209a
SC101805 Appeal Document Number 6 Page 107
HB 1
621
622
623
624
625
626
627
628
629
630
631
632
633
634
635
636
637
638
639
640
641
642
643
644
645
646
647
648
649
650
651
652
653
654
655
656
657
107
VTD: KC 207
VTD: KC 209
VTD: KC 210
VTD: KC 212
Block: 290950154012059
Block: 290950161001012
Block: 290950161001013
Block: 290950161001014
Block: 290950161001015
Block: 290950161001028
Block: 290950161001029
Block: 290950161002032
Block: 290950161002035
Block: 290950161002038
Block: 290950161002039
VTD KC 212 Subtotal
VTD: KC 213
VTD: KC 214
VTD: KC 215
VTD: KC 217
Block: 290950154012035
Block: 290950154012044
Block: 290950154012045
Block: 290950154012049
Block: 290950154012050
VTD KC 217 Subtotal
VTD: KC 218
Block: 290950154012043
Block: 290950154012048
Block: 290950154012051
Block: 290950154012052
Block: 290950154012053
Block: 290950161002031
Block: 290950161002036
Block: 290950161002037
Block: 290950161002041
VTD KC 218 Subtotal
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
210a
SC101805 Appeal Document Number 6 Page 108
HB 1
658
659
660
661
662
663
664
665
666
667
668
669
670
671
672
673
674
675
676
677
678
679
680
681
682
683
684
685
686
687
688
689
690
691
692
693
694
108
VTD: KC 2301
VTD: KC 2302
VTD: KC 2303
VTD: KC 2304
VTD: KC 2305
VTD: KC 2306
VTD: KC 2307
VTD: KC 2308
VTD: KC 2309
VTD: KC 2310
VTD: KC 2311
VTD: KC 2312
VTD: KC 2313
VTD: KC 2314
VTD: KC 2315
VTD: KC 2316
VTD: KC 2401
VTD: KC 2402
VTD: KC 2403
VTD: KC 2404
VTD: KC 2405
VTD: KC 2406
VTD: KC 2407
VTD: KC 2408
VTD: KC 2409
VTD: KC 2410
VTD: KC 2411
VTD: KC 2412
VTD: KC 2413
VTD: KC 2414
VTD: KC 2415
VTD: KC 2416
VTD: KC 2417
VTD: KC 2418
VTD: KC 2419
VTD: KC 2420
VTD: KC 2421
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
211a
SC101805 Appeal Document Number 6 Page 109
HB 1
695
696
697
698
699
700
701
702
703
704
705
706
707
708
709
710
711
712
713
714
715
716
717
718
719
720
721
722
723
724
725
726
727
728
729
730
731
109
VTD: KC 2422
VTD: KC 2423
VTD: KC 2424
VTD: KC 2425
VTD: KC 2426
VTD: KC 2427
VTD: KC 2428
VTD: KC 2429
VTD: KC 2430
VTD: KC 2431
VTD: KC 2501
VTD: KC 2503
Block: 290950129064013
Block: 290950129064014
Block: 290950132081009
Block: 290950132101000
Block: 290950132101001
Block: 290950132101004
Block: 290950132101005
Block: 290950132101008
Block: 290950132101009
Block: 290950132101010
Block: 290950144001046
Block: 290950144001047
Block: 290950144001048
Block: 290950144001049
Block: 290950144001050
Block: 290950144001051
Block: 290950144001054
Block: 290959883001000
Block: 290959883001001
Block: 290959883001002
Block: 290959883001003
Block: 290959883001005
Block: 290959883001006
Block: 290959883001008
Block: 290959883001009
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
212a
SC101805 Appeal Document Number 6 Page 110
HB 1
732
733
734
735
736
737
738
739
740
741
742
743
744
745
746
747
748
749
750
751
752
753
754
755
756
757
758
759
760
761
762
763
764
765
766
767
768
110
Block: 290959883001010
Block: 290959883001033
VTD KC 2503 Subtotal
VTD: KC 2504
VTD: KC 2505
VTD: KC 2506
VTD: KC 2507
VTD: KC 2508
Block: 290950131001010
Block: 290950132033004
Block: 290950132033005
Block: 290950132034003
Block: 290950132034004
Block: 290950132034005
Block: 290950132034006
Block: 290950132034007
Block: 290950132034008
Block: 290950132034009
Block: 290950132034010
Block: 290950132034011
Block: 290950132034012
Block: 290950132034013
Block: 290950132034014
Block: 290950132082000
Block: 290950132082001
Block: 290950132082002
Block: 290950132082003
Block: 290950132082015
Block: 290950132082017
VTD KC 2508 Subtotal
VTD: KC 2509
VTD: KC 2513
VTD: KC 2514
VTD: KC 2601
VTD: KC 2602
VTD: KC 2603
VTD: KC 2604
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
213a
SC101805 Appeal Document Number 6 Page 111
HB 1
769
770
771
772
773
774
775
776
777
778
779
780
781
782
783
784
785
786
787
788
789
790
791
792
793
794
795
796
797
798
799
800
801
802
803
804
805
111
VTD: KC 2605
VTD: KC 2606
VTD: KC 2607
VTD: KC 2608
VTD: KC 2609
VTD: KC 2610
VTD: KC 2611
VTD: KC 2612
VTD: KC 2613
VTD: KC 301
VTD: KC 302
VTD: KC 303
VTD: KC 304
VTD: KC 305
VTD: KC 306
VTD: KC 307
VTD: KC 308
VTD: KC 309
VTD: KC 310
VTD: KC 311
VTD: KC 312
VTD: KC 313
VTD: KC 314
VTD: KC 315
VTD: KC 316
VTD: KC 317
VTD: KC 318
VTD: KC 701
VTD: KC 702
VTD: KC 703
VTD: KC 704
VTD: KC 705
VTD: KC 706
VTD: KC 707
VTD: KC 708
VTD: KC 709
VTD: KC 710
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
214a
SC101805 Appeal Document Number 6 Page 112
HB 1
806
807
808
809
810
811
812
813
814
815
816
817
818
819
820
821
822
823
824
825
826
827
828
829
830
831
832
833
834
835
836
837
838
839
840
841
842
112
VTD: KC 711
VTD: KC 712
VTD: KC 713
VTD: KC 714
VTD: KC 715
VTD: KC 716
VTD: KC 717
VTD: KC 718
VTD: KC 809
Block: 290950086001010
Block: 290950086001012
VTD KC 809 Subtotal
VTD: KC 811
VTD: KC 905
VTD: KC 913
VTD: KC WD13 PCT1302
VTD: KC WD2 PCT205
VTD: KC WD2 PCT206
VTD: KC WD2 PCT211
Block: 290950018004000
Block: 290950018004001
Block: 290950018004002
Block: 290950018004003
Block: 290950018004005
Block: 290950018004006
Block: 290950018004007
Block: 290950018004008
Block: 290950018004009
Block: 290950018004010
Block: 290950018004011
Block: 290950018004012
Block: 290950018004013
Block: 290950018004014
Block: 290950018004015
Block: 290950160001000
Block: 290950160001001
Block: 290950160001002
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
215a
SC101805 Appeal Document Number 6 Page 113
HB 1
843
844
845
846
847
848
849
850
851
852
853
854
855
856
857
858
859
860
861
862
863
864
865
866
867
868
869
870
871
872
873
874
875
876
877
878
879
113
Block: 290950160001003
Block: 290950160001004
Block: 290950160001005
Block: 290950160001006
Block: 290950160001007
Block: 290950160001008
Block: 290950160001009
Block: 290950160001010
Block: 290950160001011
Block: 290950160001012
Block: 290950160001013
Block: 290950160001014
Block: 290950160001015
Block: 290950160001016
Block: 290950160001017
Block: 290950160001018
Block: 290950160001019
Block: 290950160001020
Block: 290950160001021
Block: 290950160001022
Block: 290950160001023
Block: 290950160001024
Block: 290950160001025
Block: 290950160001028
Block: 290950160001029
Block: 290950160001030
Block: 290950160001032
Block: 290950160001033
Block: 290950160001034
Block: 290950160001035
Block: 290950160001036
Block: 290950160001037
Block: 290950160001038
Block: 290950160001039
Block: 290950160001051
Block: 290950160001052
VTD KC WD2 PCT211 Subtotal
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
216a
SC101805 Appeal Document Number 6 Page 114
HB 1
880
881
882
883
884
885
886
887
888
889
890
891
892
893
894
895
896
897
898
899
900
901
902
903
904
905
906
907
908
909
910
911
912
913
914
915
916
114
VTD: KC1314
VTD: Prairie 27
Block: 290950185003004
VTD Prairie 27 Subtotal
VTD: Prairie 29
Block: 290950185003000
Block: 290950185003001
Block: 290950185003002
Block: 290950185003003
Block: 290950193022014
VTD Prairie 29 Subtotal
VTD: Prarie 01
VTD: Sni-A-Bar 01
VTD: Sni-A-Bar 02
Block: 290950145031003
Block: 290950145031004
Block: 290950145031013
Block: 290950145031014
Block: 290950193012014
Block: 290950193022000
Block: 290950193022009
Block: 290950193022010
Block: 290950193022011
Block: 290950193022019
VTD Sni-A-Bar 02 Subtotal
VTD: Sni-A-Bar 03
Block: 290950193022006
Block: 290950193022007
Block: 290950193022008
VTD Sni-A-Bar 03 Subtotal
VTD: Sni-A-Bar 04
VTD: Sni-A-Bar 05
VTD: Sni-A-Bar 06
VTD: Sni-A-Bar 07
Block: 290950148041042
Block: 290950148041043
Block: 290950148041044
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
217a
SC101805 Appeal Document Number 6 Page 115
HB 1
917
918
919
920
921
922
923
924
925
926
927
928
929
930
931
932
933
934
935
936
937
938
939
940
941
942
943
944
945
946
947
948
949
950
951
952
953
115
Block: 290950149033024
Block: 290950149033025
Block: 290950149033026
Block: 290950149033027
Block: 290950149033028
Block: 290950149041000
Block: 290950149041001
Block: 290950149041004
Block: 290950149041010
Block: 290950149041011
Block: 290950149041012
Block: 290950149052005
Block: 290950149052006
Block: 290950149054000
Block: 290950149054001
Block: 290950149054011
VTD Sni-A-Bar 07 Subtotal
VTD: Sni-A-Bar 08
Block: 290950148042027
Block: 290950148042028
Block: 290959892001006
VTD Sni-A-Bar 08 Subtotal
VTD: Sni-A-Bar 14
Block: 290950140091012
Block: 290950149051000
Block: 290950149052014
Block: 290950149052015
Block: 290950149052026
VTD Sni-A-Bar 14 Subtotal
VTD: Sni-A-Bar 16
Block: 290950140083002
Block: 290950141221004
Block: 290950141221005
Block: 290950141221010
Block: 290950141221021
Block: 290950141281026
Block: 290950141281027
Electronically Filed - Cole Circuit - August 04, 2026 - 05:02 PM
218a
SC101805 Appeal Document Number 6 Page 116
HB 1
954
955
956
957
958
959
960
961
962
963
964
965
966
967
968
969
970
971
972
973
974
975
976
977
978
979
980
981
982
983
984
985
986
987
988
989
990
116
Block: 290950141281029
VTD Sni-A-Bar 16 Subtotal
VTD: Sni-A-Bar 37
Block: 290950140021004
Block: 290950140021005
Block: 290950140021008
Block: 290950140021010
Block: 290950140021012
Block: 290950140021013
Block: 290950140021016
Block: 290950140063005
Block: 290950140063007
Block: 290950140063013
Block: 290950140063019
Block: 290950140063020
VTD Sni-A-Bar 37 Subtotal
VTD: Sni-A-Bar 38
VTD: Sni-A-Bar 39
VTD: Sni-A-Bar 40
VTD: Sni-A-Bar 41
Block: 290950140081000
Block: 290950140081001
Block: 290950140081002
Block: 290950140081003
Block: 290950140081004
Block: 290950140081005
Block: 290950140081006
Block: 290950140081007
Block: 290950140081008
Block: 290950140081009
Block: 290950140081010
Block: 290950140081011
Block: 290950140081012
Block: 290950140081013
Block: 290950140081014
Block: 290950140081015
Block: 290950140081016
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HB 1
991
992
993
994
995
996
997
998
999
1000
1001
1002
1003
1004
1005
1006
1007
1008
1009
1010
1011
1012
1013
1014
1015
1016
1017
1018
1019
1020
1021
1022
1023
1024
1025
1026
1027
117
Block: 290950140081017
Block: 290950140081018
Block: 290950140081019
Block: 290950140082004
Block: 290950140082005
Block: 290950141281023
Block: 290950141281030
VTD Sni-A-Bar 41 Subtotal
VTD: Sni-A-Bar 42
VTD: Sni-A-Bar 43
VTD: Sni-A-Bar 44
VTD: Sni-A-Bar 45
Block: 290950140021021
Block: 290950140051020
Block: 290950140051021
Block: 290950140051022
Block: 290950140051023
Block: 290950140051024
Block: 290950140051025
Block: 290950140051026
Block: 290950140051029
Block: 290950140051030
Block: 290950140051031
Block: 290950140051032
Block: 290950140051033
Block: 290950140051034
Block: 290950140051038
Block: 290950140051043
Block: 290950140051044
Block: 290950140054011
Block: 290950140054012
Block: 290950140054013
Block: 290950140054014
Block: 290950140054017
VTD Sni-A-Bar 45 Subtotal
VTD: Sni-A-Bar 46
VTD: Sni-A-Bar 47
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HB 1
1028
1029
1030
1031
1032
1033
1034
1035
1036
1037
1038
1039
1040
1041
1042
1043
1044
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
118
VTD: Sni-A-Bar 48
VTD: Sni-A-Bar 49
VTD: Sni-A-Bar 50
VTD: Sni-A-Bar 51
VTD: Sni-A-Bar 52
County Jackson MO Subtotal
County: Johnson MO
County: Lafayette MO
County: Maries MO
County: Miller MO
County: Moniteau MO
County: Morgan MO
County: Osage MO
County: Pettis MO
County: Randolph MO
County: Saline MO
District 5 Total
128.476. The sixth congressional district shall be composed of the following:
County: Adair MO
County: Andrew MO
County: Atchison MO
County: Buchanan MO
County: Caldwell MO
County: Carroll MO
County: Chariton MO
County: Clark MO
County: Clay MO
County: Clinton MO
County: Daviess MO
County: DeKalb MO
County: Gentry MO
County: Grundy MO
County: Harrison MO
County: Holt MO
County: Jackson MO
VTD: KC 1101
Block: 290950003001001
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HB 1
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
119
Block: 290950003001002
Block: 290950003001003
Block: 290950003001004
Block: 290950003001005
Block: 290950003001006
Block: 290950003001007
Block: 290950003001008
Block: 290950003001009
Block: 290950003001010
Block: 290950003001021
Block: 290950003002001
Block: 290950003002002
Block: 290950003002006
Block: 290950003002007
Block: 290950003002008
Block: 290950003002009
Block: 290950003002010
Block: 290950003002011
Block: 290950003003000
Block: 290950003003001
Block: 290950003003002
Block: 290950003003003
Block: 290950003003004
Block: 290950003003005
Block: 290950003003006
Block: 290950003003007
Block: 290950003003008
Block: 290950003003009
Block: 290950003003012
Block: 290950003003013
Block: 290950003003014
Block: 290950003003017
Block: 290950003003018
Block: 290950003003019
Block: 290950003003023
Block: 290950003003027
VTD KC 1101 Subtotal
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SC101805 Appeal Document Number 6 Page 120
HB 1
58
59
60
61
62
63
64
65
66
67
68
69
70
71
72
73
74
75
76
77
78
79
80
81
82
83
84
85
86
87
88
89
90
91
92
93
94
120
VTD: KC 1102
VTD: KC 1103
VTD: KC 1104
VTD: KC 1105
VTD: KC 1106
VTD: KC 1107
VTD: KC 1109
VTD: KC 1110
VTD: KC 1111
VTD: KC 1113
VTD: KC 1114
VTD: KC 1201
Block: 290950007002002
Block: 290950007002003
Block: 290950007002010
Block: 290950007002011
Block: 290950008001000
Block: 290950008001001
Block: 290950008001002
Block: 290950008001003
Block: 290950008001004
Block: 290950008001006
Block: 290950008001007
Block: 290950008003000
Block: 290950008003001
Block: 290950008003002
Block: 290950008003003
Block: 290950008003004
VTD KC 1201 Subtotal
VTD: KC 1202
VTD: KC 1203
VTD: KC 1204
VTD: KC 1312
VTD: KC 216
County Jackson MO Subtotal
County: Knox MO
County: Lewis MO
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HB 1
95
96
97
98
99
100
101
102
103
104
105
106
107
108
109
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
121
County: Linn MO
County: Livingston MO
County: Macon MO
County: Marion MO
County: Mercer MO
County: Nodaway MO
County: Platte MO
County: Putnam MO
County: Ray MO
County: Schuyler MO
County: Scotland MO
County: Shelby MO
County: Sullivan MO
County: Worth MO
District 6 Total
128.477. The seventh congressional district shall be composed of the following:
County: Barry MO
County: Christian MO
County: Greene MO
County: Jasper MO
County: Lawrence MO
County: McDonald MO
County: Newton MO
County: Stone MO
County: Taney MO
County: Webster MO
VTD: Benton
VTD: Diggins
VTD: Finley
VTD: Fordland
VTD: Grant
Block: 292254701022060
Block: 292254701022062
VTD Grant Subtotal
VTD: Hazelwood
VTD: Northview B
Block: 292254703022008
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HB 1
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
59
122
Block: 292254703022012
Block: 292254703022013
Block: 292254703022014
Block: 292254703022030
Block: 292254703022031
Block: 292254703022032
Block: 292254703022033
Block: 292254703022034
Block: 292254703022035
Block: 292254703023007
Block: 292254703023008
Block: 292254703023009
Block: 292254703023010
Block: 292254703023011
Block: 292254703023012
Block: 292254703023013
Block: 292254703023028
Block: 292254703023029
Block: 292254703023030
Block: 292254703023031
Block: 292254703023032
Block: 292254703023035
Block: 292254703023036
Block: 292254703023037
Block: 292254703023038
Block: 292254703023039
Block: 292254703023040
Block: 292254703023041
Block: 292254703023042
Block: 292254703023046
Block: 292254703023047
Block: 292254703023048
Block: 292254703023049
Block: 292254703023050
Block: 292254703023051
Block: 292254703023052
Block: 292254703023053
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HB 1
60
61
62
63
64
65
66
67
68
69
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
123
Block: 292254703023054
Block: 292254703023055
Block: 292254703023062
Block: 292254703023063
Block: 292254703023069
Block: 292254703023074
Block: 292254703023079
VTD Northview B Subtotal
County Webster MO Subtotal
District 7 Total
128.478. The eighth congressional district shall be composed of the following:
County: Bollinger MO
County: Butler MO
County: Cape Girardeau MO
County: Carter MO
County: Dent MO
County: Douglas MO
County: Dunklin MO
County: Howell MO
County: Iron MO
County: Jefferson MO
VTD: Airport
VTD: American Legion
VTD: Antonia
VTD: Arnold W-1
VTD: Arnold W-2
VTD: Arnold W-3
VTD: Arnold W-4
VTD: Athena
VTD: Barnhart
VTD: Brennan
Block: 290997002101000
Block: 290997002101015
Block: 290997002111000
Block: 290997002111001
Block: 290997002111002
Block: 290997002111005
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HB 1
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
59
60
61
62
63
64
124
Block: 290997002111006
Block: 290997002111007
Block: 290997002111008
Block: 290997002111010
Block: 290997002111011
Block: 290997003031000
Block: 290997003031001
Block: 290997003031002
Block: 290997003031003
Block: 290997003031004
Block: 290997003031005
Block: 290997003031006
Block: 290997003031007
Block: 290997003031008
Block: 290997003031009
Block: 290997003031010
Block: 290997003031011
Block: 290997003031012
Block: 290997003031013
Block: 290997003031014
Block: 290997003031015
Block: 290997003031016
Block: 290997003032000
Block: 290997003032001
Block: 290997003032002
Block: 290997003032003
Block: 290997003032004
Block: 290997003032005
Block: 290997003032006
Block: 290997003032007
Block: 290997003032008
Block: 290997003032009
Block: 290997003032010
Block: 290997003032011
Block: 290997003032012
Block: 290997003032013
Block: 290997003032014
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HB 1
65
66
67
68
69
70
71
72
73
74
75
76
77
78
79
80
81
82
83
84
85
86
87
88
89
90
91
92
93
94
95
96
97
98
99
100
101
125
Block: 290997003032015
Block: 290997003033000
Block: 290997003033001
Block: 290997003033002
Block: 290997003033003
Block: 290997003033004
Block: 290997003033005
Block: 290997003033006
Block: 290997003033007
Block: 290997003033008
Block: 290997003033009
Block: 290997003033010
Block: 290997003033011
Block: 290997003033012
Block: 290997003033013
Block: 290997003033014
Block: 290997003033015
Block: 290997003033016
Block: 290997003033017
Block: 290997003033018
Block: 290997003033019
Block: 290997003051000
Block: 290997003052000
Block: 290997003052026
VTD Brennan Subtotal
VTD: Crystal City W-1
VTD: Crystal City W-2
VTD: Crystal City W-3
VTD: Crystal City W-4
VTD: Festus Outside
VTD: Festus W-1
VTD: Festus W-2
VTD: Festus W-3
VTD: Festus W-4
VTD: Flamm City
VTD: Hematite
VTD: Herculaneum
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HB 1
102
103
104
105
106
107
108
109
110
111
112
113
114
115
116
117
118
119
120
121
122
123
124
125
126
127
128
129
130
131
132
133
134
135
136
137
138
126
VTD: Herculaneum W-2
VTD: Herculaneum W-3
VTD: Imperial
VTD: Imperial 2
VTD: Jefferson Heights
VTD: Jefferson R7
VTD: Kimmswick W-1
VTD: Lonedell
VTD: Mapaville
VTD: Marble Springs
VTD: Mastodon
VTD: Maxville
VTD: Meramec Heights
VTD: Miller
VTD: Murphy
VTD: North Jefferson
Block: 290997002112008
Block: 290997002112009
Block: 290997002112010
Block: 290997002112011
Block: 290997002112012
Block: 290997002112013
Block: 290997002112014
Block: 290997002112015
Block: 290997002112016
VTD North Jefferson Subtotal
VTD: Oakvale
VTD: Olympian Village
VTD: Otto
VTD: Pevely W-1
VTD: Pevely W-2
VTD: Pevely W-3
VTD: Pevely W-4
VTD: Plattin
VTD: Riverview
VTD: Rock Creek
VTD: Rock Creek 1
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HB 1
139
140
141
142
143
144
145
146
147
148
149
150
151
152
153
154
155
156
157
158
159
160
161
162
163
164
165
166
167
168
169
170
171
172
173
174
175
127
VTD: Romaine Creek
VTD: Saline
VTD: Springdale
VTD: Sunrise
VTD: Valle
Block: 290997012006056
Block: 290997013002004
Block: 290997013002005
Block: 290997013002006
Block: 290997013003000
Block: 290997013003001
Block: 290997013003002
Block: 290997013003012
Block: 290997013003026
Block: 290997014012007
Block: 290997014012012
VTD Valle Subtotal
VTD: Victoria
Block: 290997010021006
Block: 290997010021008
Block: 290997010021019
Block: 290997010021021
Block: 290997010023004
Block: 290997010023005
Block: 290997010023006
Block: 290997010023012
Block: 290997010023013
Block: 290997010023029
Block: 290997010023030
Block: 290997010023035
VTD Victoria Subtotal
VTD: Windsor
County Jefferson MO Subtotal
County: Madison MO
County: Mississippi MO
County: New Madrid MO
County: Oregon MO
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HB 1
128
176
177
178
179
180
181
182
183
184
185
186
187
188
189
190
County: Ozark MO
County: Pemiscot MO
County: Perry MO
County: Phelps MO
County: Reynolds MO
County: Ripley MO
County: Scott MO
County: Shannon MO
County: St. Francois MO
County: Ste. Genevieve MO
County: Stoddard MO
County: Texas MO
County: Wayne MO
County: Wright MO
District 8 Total
128.479. Upon the passage and enactment of sections 128.471 to 128.478, and as
2 provided to the revisor of statutes, the revisor of statutes shall publish the graphical map
3 representation of the official congressional district boundaries as an appendix of the
4 Revised Statutes of Missouri.
✔
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26AC-CC00440
Exhibit 5
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IN THE CIRCUIT COURT OF COLE COUNTY
STATE OF MISSOURI
RICHARD VON GLAHN,
Plaintiff,
v.
DENNY HOSKINS, in his official
capacity as Missouri Secretary of
State,
Defendant.
)
)
)
)
)
)
)
)
)
)
)
Case No. 26AC-CC00440
SECRETARY OF STATE’S ANSWER TO THE PETITION AND
AFFIRMATIVE DEFENSES
Defendant Denny Hoskins, in his official capacity as Missouri Secretary of
State, hereby answers the allegations in Plaintiff’s Petition and asserts affirmative
defenses as follows:
1. Admit.
2. Admit.
3. Admit.
4. Admit that paragraph 4 quotes from Missouri Constitution Article III,
Section 49. That constitutional provision speaks for itself. Defendant denies any
remaining allegations in paragraph 4.
5. Admit that paragraph 5 quotes from Missouri Constitution Article III,
Section 52(a). That constitutional provision speaks for itself. Defendant denies any
remaining allegations in paragraph 5.
1
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6. Admit that paragraph 6 quotes from Missouri Constitution Article III,
Section 52(a). That constitutional provision speaks for itself. Defendant denies any
remaining allegations in paragraph 6.
7. Admit that paragraph 7 cites a document prepared by the Secretary of
State’s Office. That document speaks for itself. Defendant denies any remaining
allegations in paragraph 7.
8. Admit.
9. Deny.
10. Admit.
11. Deny.
12. Admit.
13. Deny.
14. Admit.
15. Admit that Defendant’s lawsuit discussed in paragraph 15 related to
Plaintiff’s referendum petition.
Defendant’s papers in that lawsuit speak for
themselves. Defendant denies any remaining allegation in paragraph 15.
16. Deny.
17. Paragraph 17 purports to make a direct quotation to Exhibit 3 of the
Petition. That Exhibit speaks for itself. Defendant denies any remaining allegations
in paragraph 17.
2
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18. Admit that Defendant’s lawsuit discussed in paragraph 18 related to
Plaintiff’s referendum petition.
Defendant’s papers in that lawsuit speak for
themselves. Defendant denies any remaining allegation in paragraph 18.
19. Admit that Defendant’s lawsuit discussed in paragraph 19 related to
Plaintiff’s referendum petition.
Defendant’s papers in that lawsuit speak for
themselves. Defendant denies any remaining allegation in paragraph 19.
20. Admit.
21. Admit.
22. Admit.
23. Admit.
24. Admit.
25. Deny.
26. Deny.
27. Admit that paragraph 27 quotes § 116.120.1, RSMo. That provision speaks
for itself. Defendant denies any remaining allegations in paragraph 27.
28. Paragraph 28 appears to quote from Maggard v. State, 733 S.W.3d 411, 416
(Mo. banc 2026). That decision speaks for itself. Defendant denies any remaining
allegations in paragraph 28.
29. Paragraph 29 appears to quote from Maggard v. State, 733 S.W.3d 411, 416
(Mo. banc 2026). That decision speaks for itself. Defendant denies any remaining
allegations in paragraph 29.
3
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30. Paragraph 30 appears to quote from Maggard v. State, 733 S.W.3d 411, 416
(Mo. banc 2026). That decision speaks for itself. Defendant denies any remaining
allegations in paragraph 30.
31. Deny because Chapter 116 authorizes requires review of the “referendum
petition,” §§ 116.120, 116.150, not “the Referendum.”
32. The deadline in § 116.150.3, RSMo speaks for itself. To the extent that
paragraph 32 is inconsistent with § 116.150.3, RSMo, paragraph 32 is denied.
33. Admit to the extent that Plaintiff uses the term “the Referendum” to refer
to his referendum petition. Paragraph 33 is otherwise denied.
34. Admit.
35. Admit that paragraph 35 quotes § 116.150.2, RSMo. That provision speaks
for itself. Defendant denies any remaining allegations in paragraph 35.
36. Admit that paragraph 36 makes a representation about Exhibit 5.
Exhibit 5 speaks for itself. Defendant denies any remaining allegations in paragraph
36.
37. Admit that paragraph 37 makes a representation about § 115.125.3, RSMo.
That provision speaks for itself. Defendant denies any remaining allegations in
paragraph 37.
38. Admit.
39. Admit.
40. Deny.
41. Deny.
4
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42. Deny.
43. Deny.
44. Admit that the Secretary’s duty is to follow the law. Paragraph 44 is
otherwise denied.
45. Deny.
46. Defendant incorporates the preceding answers as if set forth fully herein.
47. Admit that paragraph 47 quotes Missouri Constitution Article III, Section
52(a). That provision speaks for itself. Defendant denies any remaining allegations
in paragraph 47.
48. To the extent that Plaintiff uses the term “the Referendum” to refer to his
referendum petition, admit the referendum petition was signed by at least 5% of
registered voters in two-thirds of Missouri’s congressional districts. Deny that any of
these signatures are valid because the referendum petition is itself unconstitutional.
49. Admit to the extent that Plaintiff uses the term “the Referendum” to refer
to his referendum petition.
50. Defendant’s certificate of insufficiency speaks for itself. Defendant denies
any allegation in paragraph 50 to the extent it conflicts with the certificate.
51. Deny.
52. Admit that paragraph 52 makes a representation about Missouri
Constitution Article III, Section 52(a). That provision speaks for itself. Defendant
denies any remaining allegations in paragraph 52.
53. Deny.
5
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54. Deny.
55. Deny.
56. Admit that paragraph 56 quotes Moore v. Harper, 600 U.S. 1 (2023). That
decision speaks for itself. Paragraph 56 is otherwise denied.
57. Admit that paragraph 57 quotes Moore v. Harper, 600 U.S. 1 (2023). That
decision speaks for itself. Paragraph 57 is otherwise denied.
58. Admit that paragraph 58 quotes Moore v. Harper, 600 U.S. 1 (2023). That
decision speaks for itself. Paragraph 58 is otherwise denied.
59. Deny.
60. Deny.
61. Deny.
Deny that Plaintiffs are entitled to any of the relief requested in the
“WHEREFORE” clause following paragraph 61, including the relief requested in
paragraphs a–c, or any relief whatsoever.
AFFIRMATIVE DEFENSES
1. Plaintiff’s claims are foreclosed by the U.S. Constitution’s Elections Clause.
See U.S. Const. art. I, § 4.
2. Plaintiff’s claims are foreclosed by the Missouri Constitution, including but
not limited to Article III, Sections 1, 45, 49, and 52(a).
3. The U.S. Constitution’s Elections Clause, U.S. Const. art. I, § 4, invalidates
Article III, Section 52(b) of the Missouri Constitution as applied.
6
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4. The U.S. Constitution’s Guarantee Clause, U.S. Const. art. IV, § 4,
invalidates Article III, Section 52(b) of the Missouri Constitution as applied.
5. Plaintiff’s demanded relief is unlawful under the Uniformed and Overseas
Citizens Absentee Voting Act, 52 U.S.C. § 20302.
6. Plaintiff’s demanded relief is unlawful under Article I, Section 2 of the U.S.
Constitution.
7. Plaintiff’s demanded relief is unlawful under the Equal Protection Clause of
the U.S. Constitution.
8. Plaintiff’s demanded relief is foreclosed by the Purcell-Hadley principle. See
Purcell v. Gonzalez, 549 U.S. 1 (2006); Hadley v. Junior Coll. Dist. of Metro. Kansas
City, 460 S.W.2d 1 (Mo. banc 1970).
Date: August 18, 2026
Respectfully submitted,
CATHERINE L. HANAWAY
ATTORNEY GENERAL
/s/ Louis J. Capozzi III
Louis J. Capozzi III, #77756
Solicitor General
J. Michael Patton, #76490
Deputy Solicitor General
Office of the Attorney General
815 Olive Street, Suite 200
St. Louis, MO 63101
Tel. (573) 645-9662
Fax (573) 751-0774
Louis.Capozzi@ago.mo.gov
Michael.Patton@ago.mo.gov
Counsel for Secretary Hoskins
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CERTIFICATE OF SERVICE
I hereby certify that on August 18, 2026, the foregoing was served on counsel
for Plaintiffs via the Court’s electronic filing service.
/s/J. Michael Patton
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IN THE CIRCUIT COURT OF COLE COUNTY, MISSOURI
RICHARD VON GLAHN
Plaintiff,
v.
DENNY HOSKINS, in his official
capacity,
Defendant,
and
PUT MISSOURI FIRST,
Intervenor-Defendant.
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Case No. 26AC-CC00440
ANSWER TO PETITION FOR DECLARATORY JUDGMENT AND
INJUNCTIVE RELIEF UNDER SECTION 116.200 OF INTERVENORS
REPUBLICAN NATIONAL COMMITTEE, NATIONAL REPUBLICAN
CONGRESSIONAL COMMITTEE, AND MISSOURI REPUBLICAN
STATE COMMITTEE
Intervenors Republican National Committee, National Republican
Congressional Committee, and Missouri Republican State Committee hereby
state for their Answer to Petition for Declaratory Judgment and Injunctive
Relief under Section 116.200 as follows:
1.
Plaintiff Richard von Glahn is a Missouri citizen, resident of St.
Louis County, a taxpayer, and qualified voter in the State of Missouri.
ANSWER: Intervenors are without knowledge or information
sufficient to form a belief as to the truth of Paragraph 1 and,
therefore, deny the same.
2.
Plaintiff von Glahn is the proponent of the referendum that is the
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subject of this action.
ANSWER: Intervenors are without knowledge or information
sufficient to form a belief as to the truth of Paragraph 2 and,
therefore, deny the same.
3.
Defendant Denny Hoskins is the Secretary of State for the State of
Missouri. His principal office is in Cole County, Missouri.
ANSWER: Intervenors admit the allegations of Paragraph 3.
4.
Missourians reserved to themselves the “power to approve or reject
by referendum any act of the general assembly, except as hereinafter
provided.” Mo. Const. art. III, § 49.
ANSWER: Mo. Const. art. III, § 49 speaks for itself. To the extent
a response is required, Intervenors deny the allegations in
Paragraph 4.
5.
Article III, Section 52(a) of the Constitution identifies the sole
exceptions to the people’s referendum right: (i) “laws necessary for the
immediate preservation of the public peace, health or safety” and (ii) “laws
making appropriations for the current expenses of the state government, for
the maintenance of state institutions and for support of public schools.” Mo.
Const. art. III, § 52(a).
ANSWER: Mo. Const. art. III, § 52(a) speaks for itself. To the
extent a response is required, Intervenors deny the allegations
in Paragraph 5.
6.
To place a referendum petition before voters, a proponent must
gather signatures of “five percent of the legal voters in each of two-thirds of the
congressional districts in the state[.]” Mo. Const. art. III, § 52(a).
ANSWER: Mo. Const. art. III, § 52(a) speaks for itself. To the
extent a response is required, Intervenors deny the allegations
in Paragraph 6.
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7.
For an election taking place in 2026, a proponent must gather
106,384 signatures across six congressional districts.
ANSWER: Intervenors admit the allegations of Paragraph 7.
8.
On September 12, 2025, the General Assembly truly agreed and
finally passed—during a special session—House Bill 1 (“HB 1”) titled: “An Act
To repeal sections 128.345, and 128.348, RSMo, and to enact in lieu thereof
twelve new sections relating to the composition of congressional districts.”
ANSWER: House Bill 1 speaks for itself. To the extent a response
is required, Intervenors admit the allegations in Paragraph 8.
9.
Attached as Exhibit 1 is a true and correct copy of HB 1.
ANSWER: Exhibit 1 speaks for itself. To the extent a response is
required, Intervenors admit the allegations in Paragraph 9.
10.
HB 1 is an act of the General Assembly.
ANSWER: Intervenors admit the allegations of Paragraph 10.
11.
HB 1 is not a law necessary for the immediate preservation of the
public peace, health, or safety.
ANSWER: HB 1 speaks for itself. To the extent a response is
required, Intervenors deny the allegations of Paragraph 11.
12.
The General Assembly did not attach an emergency clause to HB
1.
ANSWER: HB 1 speaks for itself. To the extent a response is
required, Intervenors deny the allegations of Paragraph 12.
13.
HB 1 is not a law making appropriations for the current expenses
of the state government, for the maintenance of state institutions, or for
support of public schools.
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ANSWER: HB 1 speaks for itself. To the extent a response is
required, Intervenors deny the allegations of Paragraph 13.
14.
On October 15, 2025, Defendant Hoskins, the “General Assembly”
and the State of Missouri filed a lawsuit against Plaintiff in federal court,
denominated Missouri General Assembly v. von Glahn, No. 25-cv-01535 (E.D.
Mo.).
ANSWER: Intervenors admit the allegations of Paragraph 14.
15.
That lawsuit sought to prevent Plaintiff from turning in signatures
on the Referendum.
ANSWER: Defendant’s lawsuit speaks for itself. To the extent a
response is required, Intervenors deny the allegations of
Paragraph 15.
16.
Attached as Exhibit 2 is a copy of the Complaint filed in the federal
action.
ANSWER: Intervenors admit the allegations of Paragraph 16.
17.
Defendant claimed Plaintiff should not be permitted to turn in
signatures because initiating a referendum on a redistricting bill would
“violate[] both the U.S. and Missouri Constitutions.” Ex. 3 at 2.
ANSWER: Defendant’s lawsuit speaks for itself. To the extent a
response is required, Intervenors admit the allegations of
Paragraph 17.
18.
Defendant Hoskins’ position in his filings was that the referendum
would violate the Missouri Constitution regardless of the number of signatures
submitted.
ANSWER: Defendant’s lawsuit speaks for itself. To the extent a
response is required, Intervenors admit the allegations of
Paragraph 18.
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19.
Defendant Hoskins’ position in his filings was that the referendum
would violate the U.S. Constitution regardless of the number of signatures
submitted.
ANSWER: Defendant’s lawsuit speaks for itself. To the extent a
response is required, Intervenors admit the allegations of
Paragraph 19.
20.
Following expedited litigation, including Defendant seeking a
preliminary injunction, the federal court issued a decision dismissing the
federal lawsuit on December 8, 2025.
ANSWER: Intervenors admit the allegations of Paragraph 20.
21.
Attached as Exhibit 3 is a copy of the decision in the federal action.
ANSWER: Intervenors admit the allegations of Paragraph 21.
22.
On December 9, 2025, Plaintiff submitted more than 300,000
signatures in support of the Referendum to the Secretary’s Office.
ANSWER: Intervenors are without knowledge or information
sufficient to form a belief as to the truth of Paragraph 22 and,
therefore, deny the same.
23.
The Secretary accepted the Referendum for filing and issued a
receipt for 691 boxes of signatures.
ANSWER: Intervenors admit the allegations of Paragraph 23.
24.
Each referendum petition page Plaintiff submitted to Defendant
Hoskins was identical to the form approved by his office on October 14, 2025.
ANSWER: Intervenors are without knowledge or information
sufficient to form a belief as to the truth of Paragraph 24 and,
therefore, deny the same.
25.
Attached hereto as Exhibit 4 is a true and correct copy of the
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October 14, 2025 approval of the referendum petition as to form.
ANSWER: Intervenors are without knowledge or information
sufficient to form a belief as to the truth of Paragraph 25 and,
therefore, deny the same.
26.
Each referendum petition page submitted to Defendant Hoskins
included a completed and signed circulator’s affidavit.
ANSWER: Intervenors are without knowledge or information
sufficient to form a belief as to the truth of Paragraph 26 and,
therefore, deny the same.
27.
By statute, Defendant Hoskins is required to “examine the
[Referendum] to determine whether it complies with the Constitution of
Missouri and with this chapter [116].” § 116.120.1, RSMo.
ANSWER: The statute speaks for itself. To the extent a response
is required, Intervenors admit the allegations in Paragraph 27.
28.
In doing so, Defendant Hoskins “may rely on the circulator’s
affidavit found on each page of the petition as required by section 116.080 and
116.130.1, or [he] may verify the petition signatures by use of random
sampling.”
ANSWER: The statute speaks for itself. To the extent a response
is required, Intervenors admit the allegations in Paragraph 28.
29.
“Based on this sampling, [Defendant Hoskins] can approve or
reject the petition signatures or proceed to a verification of all the signatures.”
ANSWER: The statute speaks for itself. To the extent a response
is required, Intervenors admit the allegations in Paragraph 29.
30.
“With or without sampling, [Defendant Hoskins] has discretion to
order the local election authorities to verify all the signatures.”
ANSWER: The statute speaks for itself. To the extent a response
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is required, Intervenors admit the allegations in Paragraph 30.
31.
Chapter 116 requires Defendant Hoskins to issue a certificate
deeming the Referendum sufficient or insufficient, which decision is subject to
review by the courts.
ANSWER: The statute speaks for itself. To the extent a response
is required, Intervenors deny the allegations in Paragraph 31.
32.
Chapter 116 gave Defendant Hoskins until August 4, 2026 to issue
such certificate.
ANSWER: The statute speaks for itself. To the extent a response
is required, Intervenors admit the allegations in Paragraph 32.
33.
On August 4, 2026, Defendant issued a certificate of insufficiency
for the Referendum pursuant to § 116.150, RSMo.
ANSWER: Intervenors admit the allegations of Paragraph 33.
34.
Attached as Exhibit 5 is a copy of Defendant Hoskins’ certificate of
insufficiency.
ANSWER: Intervenors admit the allegations of Paragraph 34.
35.
Defendant Hoskins is required to “stat[e] the reason for the
insufficiency.” § 116.150.2, RSMo.
ANSWER: The statute speaks for itself. To the extent a response
is required, Intervenors admit the allegations in Paragraph 35.
36.
The only reason for insufficiency identified in Defendant Hoskins’
certificate is his assertion that the referendum violates the Missouri and U.S.
Constitutions. See Ex. 5.
ANSWER: Exhibit 5 speaks for itself. To the extent a response is
required, Intervenors deny the allegations in Paragraph 36.
37.
By law, no changes can be made to the November general election
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ballots after September 8, 2026. See § 115.125.3, RSMo.
ANSWER: The statute speaks for itself. To the extent a response
is required, Intervenors admit the allegations in Paragraph 37.
38.
Plaintiff filed this Petition within 10 days of Defendant Hoskins
issuing the certificate of insufficiency.
ANSWER: Intervenors admit the allegations of Paragraph 38.
39.
Plaintiff’s challenge to that certificate is therefore timely. §
116.200.1, RSMo.
ANSWER: Paragraph 39 is a legal conclusion to which no answer
is required. To the extent an answer is required, Intervenors
deny the allegations of Paragraph 39.
PLAINTIFF IS ENTITLED TO AN INJUNCTION
40.
Plaintiff has no adequate remedy at law.
ANSWER: Intervenors deny the allegations of Paragraph 40.
41.
Plaintiff will face irreparable harm absent an order enjoining the
Secretary of State from further implementing or using the congressional
districts contained in HB 1.
ANSWER: Intervenors deny the allegations of Paragraph 41.
42.
Plaintiff is the proponent of the referendum petition and he is
entitled to the immediate suspension of the use and implementation of HB 1.
ANSWER: Intervenors deny the allegations of Paragraph 42.
43.
Plaintiff’s referendum right will be undermined if the Secretary is
allowed to further implement or make use of HB 1.
ANSWER: Intervenors deny the allegations of Paragraph 43.
44.
The Secretary faces no harm because the his duty is to carry out
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the election laws of Missouri and he should have no preference for which
congressional districts are used.
ANSWER: Intervenors deny the allegations of Paragraph 44.
45.
The public interest is served by restraining the Secretary from
taking further steps to implement or use the congressional districts in HB 1 to
ensure that the referendum right is fully realized and that the correct
congressional districts are utilized to conduct the 2026 general congressional
election.
ANSWER: Intervenors deny the allegations of Paragraph 45.
COUNT I:
THE REFERENDUM IS SUFFICIENT
46.
Plaintiff incorporates the preceding allegations as if set forth fully
herein.
ANSWER: In response to Paragraph 46, Intervenors adopt and
incorporate its answers to preceding paragraphs as fully stated
herein.
47.
The Missouri Constitution requires that referendum petitions be
“signed by five percent of the legal voters in each of two-thirds of the
congressional districts in the state.” Mo. Const. art. III, § 52(a).
ANSWER: Mo. Const. art. III, § 52(a) speaks for itself. To the
extent a response is required, Intervenors deny the allegations
in Paragraph 47.
48.
The Referendum was signed by the constitutionally required
number of legal voters in each of two-thirds of Missouri’s congressional
districts.
ANSWER: Intervenors are without knowledge or information
sufficient to form a belief as to the truth of Paragraph 26 and,
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therefore, deny the same.
49.
Defendant Hoskins did not identify the number of signatures
gathered as a reason for deeming the Referendum insufficient. See Ex. 5.
ANSWER: Intervenors are without knowledge or information
sufficient to form a belief as to the truth of Paragraph 26 and,
therefore, deny the same.
50.
Defendant Hoskins instead contends the Missouri and U.S.
Constitutions prohibit subjecting a redistricting bill to the referendum.
ANSWER: Intervenors deny the allegations of Paragraph 50.
51.
They do not.
ANSWER: Intervenors deny the allegations of Paragraph 51.
52.
The Missouri Constitution identifies only two categories of bills
exempt from the referendum: (1) bills addressing specified emergencies and (2)
specified appropriations bills. Mo. Const. art. III, § 52(a).
ANSWER: Mo. Const. art. III, § 52(a) speaks for itself. To the
extent a response is required, Intervenors deny the allegations
in Paragraph 52.
53.
HB 1 falls into neither of those categories.
ANSWER: HB 1 speaks for itself. To the extent a response is
required, Intervenors deny the allegations in Paragraph 53.
54.
The Referendum does not violate the Missouri Constitution and it
is sufficient.
ANSWER: Intervenors deny the allegations of Paragraph 54.
55.
Like the Missouri Constitution, the U.S. Constitution does not
prohibit a state from subjecting a redistricting bill to the referendum.
ANSWER: Intervenors deny the allegations of Paragraph 55.
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56.
Just three years ago, the Supreme Court “embraced the core
principle espoused in Hildebrant and Smiley that redistricting is a legislative
function, to be performed in accordance with the State’s prescriptions for
lawmaking, which may include the referendum and the Governor’s veto.”
Moore v. Harper, 600 U.S. 1, 25 (2023) (quotations omitted).
ANSWER: Moore v. Harper speaks for itself. To the extent a
response is required, Intervenors deny the allegations in
Paragraph 56.
57.
The Court squarely “rejected the contention that the Elections
Clause vests state legislatures with exclusive and independent authority when
setting the rules governing federal elections.” Id. at 26.
ANSWER: Moore v. Harper speaks for itself. To the extent a
response is required, Intervenors deny the allegations in
Paragraph 57.
58.
Put simply: “A state legislature may not create congressional
districts independently of requirements imposed by the state constitution with
respect to the enactment of laws.” Id. at 26 (quotations omitted).
ANSWER: Moore v. Harper speaks for itself. To the extent a
response is required, Intervenors deny the allegations in
Paragraph 58.
59.
All laws, except for emergency laws and appropriations, are
subject to the referendum under the Missouri Constitution.
ANSWER: Intervenors deny the allegations of Paragraph 59.
60.
The Referendum does not violate the U.S. Constitution and it is
sufficient.
ANSWER: Intervenors deny the allegations of Paragraph 60.
61.
Plaintiff is entitled to an order reversing Defendant Hoskins’
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certification decision.
ANSWER: Intervenors deny the allegations of Paragraph 61.
WHEREFORE,
having
fully
answered,
Intervenors
Republican
National Committee, National Republican Congressional Committee, the
Missouri Republican State Committee move the Court for dismissal of the
Petition, that Plaintiff takes nothing thereby, and that Intervenors be awarded
the costs and expenses incurred in the action, including attorney fees, and for
such other and further relief as is just and proper.
DEFENSES AND AFFIRMATIVE DEFENSES
The Petition fails to state a claim as a matter of law.
Plaintiff has shown no individual harm and thus has no interest, aside
from a purely conjectural interest, in the claims and therefore has no standing
to bring the action.
Plaintiff’s claims are purely speculative as to the effect of the Defendant’s
actions with respect to the referendum petition and thus such claims are not
ripe for adjudication.
The Petition raises nonjusticiable political questions that this Court has
no jurisdiction to address.
The Petition rests on erroneous statements of law and/or fact.
The Petition seeks relief foreclosed by Missouri and/or federal law.
The Petition seeks relief foreclosed Purcell v. Gonzalez, 549 U.S. 1 (2006).
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Respectfully submitted,
ELLINGER BELL LLC
By:
By:
/s/ Marc H. Ellinger
Marc H. Ellinger, #40828
Stephanie S. Bell, #61855
Cole D. Bradbury, #62760
308 East High Street, Suite 300
Jefferson City, MO 65101
Telephone: (573) 750-4100
Facsimile: (314) 334-0450
E-mail: mellinger@ellingerlaw.com
E-mail: sbell@ellingerlaw.com
E-mail: cbradbury@ellingerlaw.com
JONES DAY
/s/ John M. Gore
John M. Gore (pro hac vice forthcoming)
51 Louisiana Ave., NW
Washington, DC 20001
Telephone: (202) 879-3930
Facsimile: (202) 626-1700
E-mail: jmgore@jonesday.com
Attorneys for Intervenors
CERTIFICATE OF SERVICE
I hereby certify that a true and accurate copy of the foregoing was served
via the Court’s electronic filing system on August 9, 2026 on all parties of
record.
/s/ Marc H. Ellinger
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IN THE CIRCUIT COURT OF COLE COUNTY
STATE OF MISSOURI
RICHARD VON GLAHN,
Plaintiff,
v.
DENNY HOSKINS, in his official
capacity as Missouri Secretary of
State,
Defendant.
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Case No. 26AC-CC00440
SECRETARY OF STATE’S PRE-TRIAL BRIEF
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TABLE OF CONTENTS
TABLE OF AUTHORITIES .......................................................................................... ii
INTRODUCTION .......................................................................................................... 1
BACKGROUND ............................................................................................................. 6
LEGAL STANDARDS ................................................................................................. 12
I.
II.
III.
The State’s Authority to Enact and Enforce HB 1. ......................................... 12
Section 116.200, RSMo. .................................................................................... 12
Supremacy of Federal Law. .............................................................................. 13
ARGUMENT ................................................................................................................ 14
I.
II.
III.
IV.
Congressional maps are not subject to the Missouri Constitution’s referendum
provisions........................................................................................................... 14
A.
The U.S. Constitution’s Elections Clause requires a clear statement to
divest the Missouri General Assembly of its redistricting authority. .. 14
B.
The Missouri Constitution contains no clear statement divesting the
General Assembly of redistricting authority......................................... 20
C.
Even read without reference to the U.S. Constitution’s Elections Clause,
the Missouri Constitution does not authorize referenda on congressional
maps. ....................................................................................................... 27
The U.S. Constitution renders Article III, Section 52(b) of Missouri
Constitution invalid as applied to HB 1........................................................... 31
Changing the congressional map at this hour is impossible. Thus, the HadleyPurcell principle forbids von Glahn’s impossible demand............................... 36
The U.S. Constitution and federal law forbid changing Missouri’s
congressional map during an election. ............................................................. 43
A.
An order requiring the State to host a new Primary Election would force
a violation of 52 U.S.C. § 20302 (“UOCAVA”). ...................................... 44
B.
An order requiring a General Election under a different map would
violate the U.S. Constitution. ................................................................ 45
CONCLUSION............................................................................................................. 49
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TABLE OF AUTHORITIES
Cases
Abbott v. LULAC,
146 S. Ct. 418 (2025) ............................................................................................ 4, 38
Ali v. Fed. Bureau of Prisons,
552 U.S. 214 (2008) .................................................................................................. 20
Ariz. State Legislature v. Ariz. Indep. Redistricting Comm’n,
576 U.S. 787 (2015) ........................................................................................ 2, 19, 24
Armstrong v. Exceptional Child Ctr., Inc.,
575 U.S. 320 (2015) .................................................................................................. 27
Carson v. Simon,
978 F.3d 1051 (8th Cir. 2020) .................................................................................. 16
Collins v. Yellen,
594 U.S. 220 (2021) .................................................................................................. 15
Covington v. North Carolina,
316 F.R.D. 117 (M.D.N.C. 2016) .............................................................................. 43
Duncan v. McCall,
139 U.S. 449 (1891) .................................................................................................. 35
Edmond v. United States,
520 U.S. 651 (1997) .................................................................................................. 15
FDA v. Brown & Williamson,
529 U.S. 120 (2000) .................................................................................................. 15
Felker v. Turpin,
518 U.S. 651 (1996) .................................................................................................. 15
Foster v. Love,
522 U.S. 67 (1997) .................................................................................................... 44
Gray v. Sanders,
372 U.S. 368 (1963) .................................................................................................. 47
Gregory v. Ashcroft,
501 U.S. 452 (1991) .................................................................................................. 15
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Hadley v. Junior Coll. Dist. of Metro. Kansas City,
460 S.W.2d 1 (Mo. banc 1970) .............................................................................. 4, 37
Harper v. Virginia State Bd. of Elections,
383 U.S. 663 (1966.................................................................................................... 30
Hawke v. Smith,
253 U.S. 221 (1920) .................................................................................................. 14
Healey v. State,
732 S.W.3d 827 (Mo. banc 2026) .................................................................... 1, 12, 23
Luther v. Hoskins,
730 S.W.3d 567 (Mo. banc 2026) ...................................................................... passim
Madden v. Missouri Pac. Ry. Co.,
192 S.W. 455 (Mo. banc 1917) .................................................................................. 35
Maggard v. State,
733 S.W.3d 411 (Mo. banc 2026) ...................................................................... passim
Mejia Olalde v. Noem,
No. 1:25-CV-00168-JMD, 2025 WL 3131942 (E.D. Mo. Nov. 10, 2025) ................. 27
Merrill v. Milligan,
142 S. Ct. 879 (2022) ................................................................................................ 39
Minor v. Happersett,
88 U.S. 162 (1874) .............................................................................................. 33, 34
Missouri Gen. Assembly v. von Glahn,
No. 4:25-CV-1535-ZMB, 2025 WL 3514277 (E.D. Mo. Dec. 8, 2025) .................. 8, 26
Missouri Gen. Assembly v. von Glahn,
No. 4:25-CV-1535-ZMB, 2026 WL 1290477 (E.D. Mo. May 11, 2026) .................... 26
Moore v. Harper,
600 U.S. 1 (2023) ...................................................................................................... 19
No Bans on Choice v. Ashcroft,
638 S.W.3d 484 (Mo. banc 2022) ........................................................................ 23, 26
Page v. Va. State Bd. of Elections,
58 F. Supp. 3d 533 (E.D. Va. 2014) .......................................................................... 43
iii
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People Not Politicians v. Hoskins,
736 S.W.3d 518 (Mo. App. W.D. 2026) ................................................................. 3, 23
Priorities USA v. State,
591 S.W.3d 448 (Mo. banc 2020) ........................................................................ 29, 30
Purcell v. Gonzalez,
549 U.S. 1 (2006) ...................................................................................................... 38
Reynolds v. Sims,
377 U.S. 533 (1964) .................................................................................................. 30
Robinson v. Missouri Dept. of Health and Sr. Services,
No. 20AC-CC00515, 2021 WL 7441868 (Mo.Cir. Nov. 26, 2021) ............................ 34
Smiley v. Holm,
285 U.S. 355 (1932) .................................................................................................. 32
Smith v. Allwright,
321 U.S. 649 (1944) .................................................................................................. 46
Sossamon v. Texas,
563 U.S. 277 (2011) .................................................................................................. 15
St. Louis Cnty. Bd. of Election Commissioners v. McShane,
492 S.W.3d 177 (Mo. App. E.D. 2016) ...................................................................... 29
State ex rel. Gordon v. Becker,
49 S.W.2d 146 (Mo. banc 1932) ................................................................................ 22
State ex rel. Jones v. Atterbury,
300 S.W.2d 806 (Mo. banc 1957) .............................................................................. 29
State ex rel. Kemper v. Carter,
165 S.W. 773 (Mo. banc 1914) .................................................................................. 26
State ex rel. McClellan v. Kirkpatrick,
504 S.W.2d 83 (Mo. banc 1974) ................................................................................ 46
State ex rel. Moore v. Toberman,
250 S.W.2d 701 (Mo. banc 1952) .............................................................................. 21
State of Ohio ex rel. Davis v. Hildebrandt,
241 U.S. 565 (1916) ............................................................................................ 19, 32
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State v. Liberty,
370 S.W.3d 537 (Mo. banc 2012) .............................................................................. 21
Terrazas v. Slagle,
821 F. Supp. 1154 (W.D. Tex. 1992) ........................................................................ 43
United States v. Caldwell,
No. CV 26-2025 (ZNQ) (JTQ), 2026 WL 2186515 (D.N.J. July 29, 2026) ........ 16, 19
United States v. Classic,
313 U.S. 299 (1941) ............................................................................................ 46, 48
United States v. Gradwell,
243 U.S. 476 (1917) .......................................................................................... passim
United States v. Missouri,
114 F.4th 980 (8th Cir. 2024) ................................................................................... 13
United States v. Mosley,
238 U.S. 383 (1915) .................................................................................................. 45
United States v. Oregon,
828 F. Supp. 3d 1092 (D. Or. 2026).................................................................... 16, 19
Vera v. Richards,
861 F. Supp. 1304 (S.D. Tex. 1994) .......................................................................... 43
Wesberry v. Sanders,
376 U.S. 1 (1964) ................................................................................................ 25, 30
West Virginia v. EPA,
597 U.S. 697 (2022) .................................................................................................. 15
Statutes
§ 115.121, RSMo .................................................................................................. passim
§ 115.339, RSMo .......................................................................................................... 46
§ 115.341, RSMo ................................................................................................ 2, 37, 38
§ 115.343, RSMo .................................................................................................... 46, 48
§ 115.349, RSMo ................................................................................................ 5, 36, 38
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§ 115.363, RSMo .......................................................................................................... 48
§ 115.508, RSMo .......................................................................................................... 44
§ 115.920, RSMo .......................................................................................................... 44
§ 116.120, RSMo ...................................................................................................... 8, 11
§ 116.140, RSMo ............................................................................................................ 8
§ 116.150, RSMo .................................................................................................. 2, 9, 24
§ 116.200, RSMo ................................................................................................ 8, 11, 12
§ 116.334, RSMo ...................................................................................................... 2, 23
2 U.S.C. § 7..................................................................................................................... 6
52 U.S.C. § 20302 ............................................................................................... 6, 41, 44
52 U.S.C. § 20307 ......................................................................................................... 45
Mo. Const. art. I, § 4 .............................................................................................. 13, 31
Mo. Const. art. III, § 45 ............................................................................. 10, 20, 27, 30
Mo. Const. art. III, § 49 ............................................................................... 7, 15, 20, 25
Mo. Const. art. III, § 52(a) ................................................................................... passim
Mo. Const. art. III, § 52(b) ................................................................................... passim
Mo. Const. art. III, § 7 ................................................................................................. 22
Mo. Const. art. V, § 3 ................................................................................................... 13
U.S. Const. amend. XIV, § 1 .................................................................................... 6, 47
U.S. Const. amend. XIV, § 2 ........................................................................................ 14
U.S. Const. amend. XIV, § 3 ........................................................................................ 14
U.S. Const. amend. XVII ............................................................................................. 14
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U.S. Const. amend. XVIII, § 3 ..................................................................................... 14
U.S. Const. amend. XX, § 6 ......................................................................................... 15
U.S. Const. amend. XXII, § 2....................................................................................... 15
U.S. Const. art. I, § 2 ................................................................................... 6, 14, 29, 45
U.S. Const. art. I, § 3 ................................................................................................... 14
U.S. Const. art. I, § 4 ........................................................................................... 2, 7, 14
U.S. Const. art. I, § 8 ................................................................................................... 14
U.S. Const. art. II, § 1 .................................................................................................. 14
U.S. Const. art. IV, § 3 ................................................................................................. 14
U.S. Const. art. IV, § 4 ................................................................................. 2, 14, 33, 35
U.S. Const. art. V ......................................................................................................... 14
U.S. Const. art. VI ........................................................................................... 13, 14, 31
Other Authorities
Federalist No. 10 (Madison) ........................................................................................ 34
Institution, CAMBRIDGE DICTIONARY ........................................................................... 29
Institution, MERRIAM WEBSTER DICTIONARY ............................................................... 29
Jason Hancock, Referendum campaign asks court to block new Missouri map from
November election, MISSOURI INDEPENDENT (Aug. 5, 2026) .................................... 45
Jen Rice & Yunior Rivas, Missouri blocks anti-gerrymander referendum from
November ballot, DEMOCRACY DOCKET (Aug. 4, 2026) .............................................. 1
Jen Rice, GOP derails bid to stop Missouri gerrymander for 2026, DEMOCRACY
DOCKET (Mar. 27, 2026) ............................................................................................. 1
Letter from George Washington to Charles Mynn Thruston (Aug. 10, 1794)........... 33
Mo. Att’y Gen., Op. Letter 03-2026 (May 13, 2026) ..................................................... 9
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INTRODUCTION
Plaintiff Richard von Glahn’s Petition is, frankly, crazy. Von Glahn says he
cares about democracy. But then, his Petition alleges that approximately 3.3% of
Missouri voters can temporarily repeal a duly enacted congressional map—even
before the People vote. Pet. ¶¶ 6–7, 42–43, 45; id. at 8. That is why von Glahn thinks
“he is entitled to the immediate suspension” of Missouri’s duly-enacted congressional
map—even though the Primary Election already occurred.
See id.
This is
unthinkable. Von Glahn cites no judicial precedent that has ever awarded such a
drastic remedy (and the State is unaware of any). Moreover, von Glahn is flatly
incorrect to argue that the Missouri Constitution permits referenda on congressional
maps like House Bill 1.
Even Democracy Docket, a leftwing media entity founded by the Democratic
Party’s leading lawyer, Marc Elias,1 calls von Glahn’s legal challenge “a long shot.”
See Ex. 33, Jen Rice & Yunior Rivas, Missouri blocks anti-gerrymander referendum
from November ballot, DEMOCRACY DOCKET (Aug. 4, 2026).2 In fact, Democracy Docket
admitted last March that this Court’s ruling in Maggard “ha[d] likely killed attempts
to stop Republicans from imposing the new map” because of the candidate-filing
deadline “rapidly approaching” on March 31, 2026. Ex. 34, Jen Rice, GOP derails bid
1 Elias’s firm, the Elias Law Group, represented plaintiffs in Healey v. State,
732 S.W.3d 827 (Mo. banc 2026)—another unsuccessful challenge to HB 1.
2 https://archive.is/FHSfJ
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to stop Missouri gerrymander for 2026, DEMOCRACY DOCKET (Mar. 27, 2026).3 Five
months later, von Glahn somehow still insists this Court should alter Missouri’s
congressional map.
The Court should reject von Glahn’s claims for at least four reasons. First, the
U.S. and Missouri Constitutions vest authority over federal redistricting solely with
the people’s elected representatives in the General Assembly. U.S. Const. art. I, § 4;
id. art. IV, § 4.
Even assuming the U.S. Constitution allows States to permit
referenda against federal election maps, but see Ariz. State Legislature v. Ariz. Indep.
Redistricting Comm’n, 576 U.S. 787, 824–50 (2015) (Roberts, C.J., dissenting),
longstanding precedent requires a “positive and clear” statement in any law or state
constitutional provision purporting to divest a state legislature of its redistricting
authority, United States v. Gradwell, 243 U.S. 476, 485 (1917). Von Glahn simply
cannot identify any language in the Missouri Constitution showing that Missourians
made a conscious choice to depart from the U.S. Constitution’s default rule and
subject congressional redistricting to referenda. See Maggard v. State, 733 S.W.3d
411, 414 n.7 (Mo. banc 2026) (reserving the question of whether the Missouri
Constitution permits referenda on congressional maps).
Indeed, Missouri law obviously does not envision referenda on redistricting. If
it did, why would local election officials and the Secretary of State have until the day
of the primary election to make a certification decision? See §§ 115.341, 116.150.3,
RSMo. And why would voters be expected to vote on redistricting plans, which are
3 https://archive.ph/pUnQs
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enormously complex, with only a 100-word summary statement and no images of the
competing maps? See § 116.334, RSMo. The idea of holding a referendum on a
congressional map under such conditions is absurd. This reinforces that Missouri
never made a “positive and clear” choice to allow such votes. See Gradwell, 243 U.S.
at 485.
Second, even if the Missouri Constitution does envision referenda on federal
congressional maps, the U.S. Constitution preempts Article III, Section 52(b) of the
Missouri Constitution—which would freeze an enacted congressional map before the
People vote. In von Glahn’s view, a small minority of Missourians—five percent of
voters in two-thirds of Missouri’s congressional districts (or about 3.3%)—have the
right to force the use of their preferred congressional map for an election cycle. See
Pet. ¶¶ 6–7, 42–43, 45; id. at 8. The U.S. Supreme Court has never suggested such
an arrangement is consistent with the U.S. Constitution’s Elections Clause. And
frankly, von Glahn’s proposed regime would be absurd. Every time redistricting
occurs, the minority political party could easily gather the signatures needed to freeze
a congressional map for one election cycle—a small price to pay for one or more
congressional seats. And imagine if this maneuver occurred after the decennial
Census, when Missouri could gain or lose a seat. A referendum campaign could force
Missouri to use an outdated congressional map with the wrong number of seats. Also,
if von Glahn can demand a referendum on a congressional map, what’s to stop him—
or anyone else—from attempting to enact a congressional map via initiative petition?
In that world, voters would need to select from six or seven competing maps based on
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a 100-word summary statement. Von Glahn cannot cite any State that has ever
permitted such an outrageous arrangement for redistricting.
And the U.S.
Constitution’s Elections Clause prohibits these absurd possibilities—which would
annihilate the General Assembly’s authority over redistricting and give small
political minorities an uncheckable power over the majority.
Third, even if referendum campaigns can freeze congressional maps by
submitting a sufficient number of signatures, it is far too late for this Court to order
the use of a new congressional map for the 2026 General Election. Missouri courts,
federal courts, and other state courts refuse to change election rules in the middle of
an ongoing election cycle. See Hadley v. Junior Coll. Dist. of Metro. Kansas City, 460
S.W.2d 1, 2–3 (Mo. banc 1970); Abbott v. LULAC, 146 S. Ct. 418, 419 (2025). Indeed,
the Missouri Supreme Court already applied this rule and held that it was too late to
change election district lines close to the end of candidate filing. Hadley, 460 S.W.2d
at 2–3. Here, candidate filing ended last March and the Primary Election is already
over. Trying to change congressional maps now would be catastrophically disruptive
and technically “impossible”—as Missouri’s election administration system will be
locked and cannot be altered. See Ex. 28, Brown Aff. ¶¶ 6–19.4
4 Accord Ex. 32, Letter of Missouri Association of County Clerks and Election
Authorities; Ex. 29, Amicus Br. of Brianna Lennon at 11–14, Maggard v. State, No.
SC101581 (Mo. banc, filed April 10, 2026); see also Ex. 30, Amicus Br. of Kurt Bahr
at 13–16, Maggard v. State, No. SC101581 (Mo. banc, filed April 28, 2026); Ex. 31,
Trial Testimony of Shawn Kieffer at 109:1–17, Healey v. State, No. 2516-CV31273
(Mo. Cir. Ct., Feb. 19, 2026).
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Indeed, litigants challenging the HB 1 map since September 2025 recognized
that the window to change the congressional map for Missouri’s 2026 elections closed
long ago. Von Glahn and People Not Politicians (“PNP”) characterized prior lawsuits
as “time-sensitive election case[s]” because of their “impact” on “the 2026 election”
and the need to avoid “chaos in August.” Ex. 22, Mot. to Expedite at 1–2, State ex rel.
People Not Politicians v. Limbaugh, No. WD88821 (Mo. App. W.D., filed April 1,
2026). In other cases, opponents of HB 1—including opponents represented by von
Glahn’s counsel—all stated that they needed judicial resolution of HB 1’s status
before the candidate-filing period opened last February.5 Many of these plaintiffs
acknowledged that equitable principles would eventually require Missouri courts “to
favor the status quo in a legal dispute during the lead-up to an election.” See, e.g.,
Ex. 26, SIS Mot. for Prelim. Inj. at 16, Maggard v. State, No. 25AC-CC09120 (Mo. Cir.
Ct., filed Jan. 14, 2026) (quotation omitted). Likewise, the Boone County Clerk—who
is now testifying for Plaintiff—previously argued that any change to Missouri’s
congressional map (even “before the August primary”) “will result in chaos, confusion,
and unnecessary expense.” Compare Ex. 29, Amicus Br. of Brianna Lennon, supra,
at 6–7, 11–14, with Ex. 21, Lennon Aff. Missouri has now completed the August
primary, § 115.121.2, RSMo, Missouri’s candidate filing period closed many months
5 See Ex. 24, Mot. to Expedite at 2, Luther v. Hoskins, No. SC101412 (Mo. banc,
filed Dec. 31, 2025); Ex. 25, Pltfs.’ Opp. to a Continuance at 1–3, Wise v. State and
Healey v. State, Nos. 2516-CV29597, 2516-CV31273 (Mo. Cir. Ct., filed Dec. 15, 2025);
Ex. 26, SIS Mot. for Prelim. Inj. at 16, Maggard v. State, No. 25AC-CC09120 (Mo. Cir.
Ct., filed Jan. 14, 2026).
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ago, § 115.349.1, RSMo, and Missouri’s General Election is just a few weeks away, id.
§ 115.121.1, RSMo. Von Glahn cannot now ignore these previous representations.
Finally, granting von Glahn’s request for an injunction against using the HB 1
congressional map for the 2026 General Election would violate federal law. Federal
law prohibits holding a new primary election because there simply is not enough
time—under the federal election calendar—to do so. See 2 U.S.C. § 7; 52 U.S.C.
§ 20302(a)(8). And while von Glahn’s counsel has publicly suggested just forcing the
winners of the Primary Election to run in his preferred congressional districts, that
would violate the U.S. Constitution’s right to equal voting by rendering pointless
hundreds of thousands of votes in the Primary Election. See U.S. Const. art. I, § 2,
amend. XIV, § 1. To avoid violating federal law, this Court should hold that the 2026
General Election must be conducted under the same map that governed the Primary
Election.
The Court should reject von Glahn’s claims, and enter judgment for the State.
BACKGROUND
On September 12, 2025, the General Assembly enacted House Bill 1, which
provided for the boundaries of Missouri’s eight congressional districts. HB 1 passed
by a margin of 21 to 11 in the Senate and 90 to 65 in the House of Representatives.
See Mo. Senate J. 25–26 (2d Extra. Sess., 103d Gen. Assembly, Sept. 12, 2025); Mo.
House J. 37–38 (2d Extra. Sess., 103d Gen. Assembly, Sept. 9, 2025). Governor Kehoe
signed HB 1 into law on September 28, 2025.
In response, a group known as People Not Politicians (“PNP”) initiated a
referendum campaign to challenge the HB 1 map. However, the Missouri General
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Assembly, the Secretary of State, and the Attorney General perceived a problem with
PNP’s undertaking: A referendum on the HB1 congressional map is in tension with
the U.S. Constitution’s Elections Clause. See U.S. Const. art. I, § 4. The Elections
Clause provides that “[t]he Times, Places and Manner of holding Elections for
Senators and Representatives, shall be prescribed in each State by the Legislature
thereof.” Id. (emphasis added). Yet a referendum on a congressional map divests the
General Assembly of legislative authority and relies instead on a statewide vote.
Almost ten months ago, to help clarify this disparity before PNP submitted its
referendum petition, the Secretary of State (alongside the General Assembly) sued
PNP and its executive director, Richard von Glahn.
Among other things, the
Secretary sought a declaratory judgment resolving the validity of PNP’s referendum
petition. See Complaint at 22, Missouri Gen. Assembly v. von Glahn, No. 4:25-cv1535 (E.D. Mo., filed Oct. 15, 2026), ECF No. 1.
He argued that the U.S.
Constitution’s Elections Clause forbids subjecting congressional maps to referenda
absent a clear statement in the Missouri Constitution. Id. ¶¶ 67–69. The Secretary
also noted that the Missouri Constitution includes no such clear statement. Id.
¶¶ 72–74. Indeed, Article III, Section 45 only recognizes the General Assembly’s
legislative authority over redistricting. And Missouri’s referendum provisions are
silent about referenda on congressional districts. See Mo. Const. art. III, §§ 49, 52(a),
52(b).
Despite the Secretary’s effort to obtain clarity last fall, the federal district court
dismissed his lawsuit as premature. It explained that under Chapter 116, RSMo, the
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Secretary of State has “both the authority and duty” to assess “the constitutionality
of [PNP’s] final petition” before courts may consider the question. Missouri Gen.
Assembly v. von Glahn, No. 4:25-CV-1535-ZMB, 2025 WL 3514277, at *4 n.4 (E.D.
Mo. Dec. 8, 2025) (citing § 116.120, RSMo). The court also expressly recognized the
Secretary’s authority to “declare [PNP’s] petition unconstitutional.” Id. * 4. Even
PNP agreed that Secretary Hoskins has “authority as Secretary of State to reject
[PNP’s] petition as unconstitutional during post-submission review and to defend
that decision based on the very same constitutional arguments” that the State
“advance[d]” in its lawsuit. Id. at *1, 4 n.4 (citing §§ 116.120, 116.200, RSMo).
PNP then submitted its referendum petition on December 9, 2025. PNP’s
submission triggered the Secretary’s duty to review the referendum petition for
timeliness, legality, and sufficiency under Chapter 116. See Maggard, 733 S.W.3d at
416 (“Section 116.120.1 provides the secretary “shall examine the petition to
determine whether it complies with the Constitution of Missouri and with this
chapter [116].’” (emphasis added)).
Section 116.150.3 required the Secretary to
complete this review process by August 4, 2026—the same day as Missouri’s Primary
Election. Chapter 116 provided an extensive timeline for reviewing the referendum
petition because it vested the Secretary and local election officials with substantial
duties.
It required Missouri’s 116 local election officials to painstakingly check
submitted signatures. See §§ 116.120–116.140, RSMo. Chapter 116 also empowers
the Secretary to independently check the validity of signatures. § 116.140, RSMo. At
the end of the exhaustive signature-review process, Chapter 116 provides that, “if the
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secretary of state finds it sufficient, the secretary of state shall issue a certificate
setting forth that the petition contains a sufficient number of valid signatures to
comply with the Constitution of Missouri and with this chapter.” § 116.150.1, RSMo.
But “[i]f the secretary of state finds the petition insufficient, the secretary of state
shall issue a certificate stating the reason for the insufficiency.” § 116.150.2, RSMo.
While the Secretary and Missouri’s 116 local election authorities were busy
reviewing the signatures on PNP’s referendum petition, the Secretary of State and
the Attorney General recognized that HB 1 would become effective pending the
Secretary’s ultimate certification decision under Chapter 116. Yet in late December
2025, two plaintiffs challenged HB 1’s statewide effectiveness. Maggard, 733 S.W.3d
at 413. They sought a declaratory judgment and “an injunction preventing use of
HB 1’s congressional map until voters approve the map through the referendum
process.” Id. However, this Court and the Missouri Supreme Court unanimously
rejected their claims, holding that “the December 9 referendum petition filing did not
automatically suspend HB 1 under article III, sections 49, 52(a), or 52(b) of the
Missouri Constitution.” Id. at 421.
After the Supreme Court’s ruling, the Attorney General released an opinion
letter requiring “State and local election officials” to “take all appropriate steps to
ensure the HB 1 map is fully implemented in advance of the 2026 primary elections.”
Mo. Att’y Gen., Op. Letter 03-2026 (May 13, 2026). Then, under the Supreme Court’s
and the Attorney General’s opinions, Missouri’s local election officials implemented
the HB 1 map in Missouri’s Centralized Voter Registration system. See Ex. 28,
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Brown Aff. ¶¶ 4, 18. After implementing the HB 1 map, State and local election
officials also prepared ballots under the new map and then completed the August
Primary Election. Id. at ¶ 4. Roughly 1.2 million voters participated in the August 4
congressional primaries, and they selected Republican and Democratic nominees in
each of Missouri’s eight congressional districts.
On August 4, 2026, the Secretary of State released his certificate of
insufficiency as to PNP’s referendum petition. See Ex. 5. The Secretary’s certificate
identified “the reason for the insufficiency” as the fact that the Missouri Constitution
does not permit referenda on congressional maps. Id. at 3. The Secretary’s certificate
relied on a letter from the Attorney General, which was attached to the certificate,
explaining that a referendum on a congressional map would be in tension with the
U.S. Constitution’s Elections Clause.
Id. at 4–10.
Thus, to divest the General
Assembly of its redistricting authority, in contravention of the Elections Clause’s
plain text, the Missouri Constitution would need to speak with a clear statement. Id.
However, the Missouri Constitution includes no such clear statement. Id. Rather,
“Article III, section 45 is the only provision of the Missouri Constitution directly
addressing congressional redistricting.” Luther v. Hoskins, 730 S.W.3d 567, 571 (Mo.
banc 2026). And Article III, Section 45 contemplates only that “the general assembly
shall by law divide the state into [congressional] districts.” Mo. Const. art. III, § 45
(emphasis added). The Attorney General’s letter also noted that, even if the Missouri
Constitution did authorize referenda on congressional maps, the HB 1 map could not
be displaced absent a majority vote in light of the U.S. Constitution’s Elections Clause
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and the Guarantee Clause. Ex. 5 at 8–9. Moreover, the Attorney General noted that
a last-minute alteration to Missouri’s congressional map would likely force violations
of UOCAVA and Article I, Section 2 of the U.S. Constitution. Id. at 9–10.
A couple hours after the Secretary’s decision, von Glahn filed suit under
§ 116.200.1, which provides that “[a]fter the secretary of state certifies a petition as
sufficient or insufficient, any citizen may apply to the circuit court of Cole County to
compel him to reverse his decision.” § 116.200.1, RSMo. Yet von Glahn’s challenge
is not just limited to the Secretary’s decision to certify PNP’s referendum petition as
insufficient for the ballot in November 2026. He also alleges that “he is entitled to
the immediate suspension of the use and implementation of HB 1.” Pet. ¶¶ 42–43; id.
at 8. Elsewhere, he alleges that the Court should “restrain[] the Secretary from
taking further steps to implement or use the congressional districts in HB 1 to ensure
that … the correct congressional districts are utilized to conduct the 2026 general
congressional election.”
Id. ¶ 45.
Von Glahn’s Petition lacks further clarity on
precisely what he means—which is particularly confusing since Missouri completed
the Primary Election about two weeks ago. See § 115.121.2, RSMo. The Court and
the State are left to guess, for example, whether von Glahn envisions a new Primary
Election under “the correct congressional districts,” Pet. ¶ 45, or whether he demands
a General Election that proceeds under a different congressional map than the HB 1
map used for the Primary. Id.
As explained below, von Glahn’s demand fails in either event.
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LEGAL STANDARDS
I.
The State’s Authority to Enact and Enforce HB 1.
Plaintiffs demand an injunction against any enforcement of the General
Assembly’s HB 1 map. Pet. ¶¶ 42–43, 45; id. at 8. But “the General Assembly has
the power to do whatever is necessary to perform its functions except as expressly
restrained by the Constitution.” Luther, 730 S.W.3d at 571 (quoting Liberty Oil Co.
v. Dir. of Revenue, 813 S.W.2d 296, 297 (Mo. banc 1991)). And “[c]onstitutional
limitations on the legislative power are ‘strictly construed in favor of the power of the
General Assembly.’” Id. (quoting Bd. of Educ. of City of St. Louis v. City of St. Louis,
879 S.W.2d 530, 533 (Mo. banc 1994)).
The Missouri Supreme Court has also
instructed that courts may “not hold HB 1 unconstitutional ‘unless it clearly
contravenes a constitutional provision.’” Id. (quoting City of St. Louis v. State, 682
S.W.3d 387, 396 (Mo. banc 2024)); accord Healey, 732 S.W.3d at 837 (“The [HB 1] map
will be upheld unless it plainly and palpably affronts fundamental law embodied in
the constitution, and doubts will be resolved in favor of the constitutionality of the
map.” (cleaned up)).
II.
Section 116.200, RSMo.
Section 116.200.1, RSMo, provides that “[a]fter the secretary of state certifies
a [referendum] petition as sufficient or insufficient, any citizen may apply to the
circuit court of Cole County to compel him to reverse his decision.” Subsection 2 then
instructs that “[i]f the court decides the petition is sufficient, the secretary of state
shall certify it as sufficient and attach a copy of the judgment.” § 116.200.2, RSMo.
But “[i]f the court decides the petition is insufficient, the court shall enjoin the
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secretary of state from certifying the measure and all other officers from printing the
measure on the ballot.” Id. Moreover, “[w]ithin ten days after a decision is rendered,
any party may appeal it to the supreme court.” § 116.200.3, RSMo.6
III.
Supremacy of Federal Law.
This action includes several questions that involve overlapping federal and
state laws.
The U.S. Constitution and the Missouri Constitution establish the
supremacy of federal law in the event of a conflict. Article VI of the U.S. Constitution
provides:
This Constitution, and the Laws of the United States which shall be made in
Pursuance thereof … shall be the supreme Law of the Land; and the Judges in
every State shall be bound thereby, any Thing in the Constitution or Laws of
any State to the Contrary notwithstanding.
U.S. Const. art. VI; United States v. Missouri, 114 F.4th 980, 986 (8th Cir. 2024)
(“[T]he states are prohibited from passing any acts which shall be repugnant to a law
of the United States.” (quotation omitted)).
The first Article of the Missouri
Constitution also enforces the federal Supremacy Clause, providing that “Missouri is
a free and independent state, subject only to the Constitution of the United States.”
Mo. Const. art. I, § 4. Thus, the U.S. Constitution and federal law are ultimately
dispositive in this action—“any Thing in the Constitution or Laws of [Missouri] to the
Contrary notwithstanding.” U.S. Const. art. VI.
6 The Missouri Constitution creates an independent basis for the Missouri
Supreme Court’s exclusive jurisdiction in this case. This action involves the validity
of Article III, Section 52(b) as applied under the U.S. Constitution’s Elections Clause
and the Guarantee Clause. See infra 31–36. And “[t]he supreme court shall have
exclusive appellate jurisdiction in all cases involving the validity … of the
constitution of this state.” Mo. Const. art. V, § 3.
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ARGUMENT
The Court should reject von Glahn’s claims. Congressional maps are not
subject to the Missouri Constitution’s referendum provisions. Even if they were, the
U.S. Constitution would invalidate Article III, Section 52(b)—which freezes referred
laws pending a statewide vote—as-applied to congressional maps. Missouri’s HadleyPurcell principle also prohibits a last-minute alterations to a congressional map after
the Primary Election and mere weeks before the General Election. Finally, the U.S.
Constitution and federal law forbid changes to Missouri’s congressional map at this
late hour.
I.
Congressional maps are not subject to the Missouri Constitution’s
referendum provisions.
A.
The U.S. Constitution’s Elections Clause requires a clear
statement to divest the Missouri General Assembly of its
redistricting authority.
The Elections Clause of the U.S. Constitution provides that “[t]he Times,
Places and Manner of holding Elections for Senators and Representatives, shall be
prescribed in each State by the Legislature thereof.” U.S. Const. art. I, § 4 (emphasis
added). The term “Legislature” was “not . . . of uncertain meaning when incorporated
into the Constitution”: It referred to “the representative body which made the laws
of the people.” Hawke v. Smith, 253 U.S. 221, 227 (1920). The term “Legislature”
maintains this same meaning throughout the U.S. Constitution. Elsewhere, the
Constitution consistently and unequivocally uses the term “Legislature” in reference
to State legislative bodies. See U.S. Const. art. I, §§ 2, 3, 8; art. II, § 1; art. IV, §§ 3,
4; art. V; art. VI; amend. XIV, §§ 2, 3; amend. XVII; amend. XVIII, § 3; amend. XX,
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§ 6; amend. XXII, § 2.
Likewise, when the Elections Clause uses the term
“Legislature” “in each State,” the Clause expressly vests the Missouri General
Assembly with authority over redistricting.
Here, as in several other contexts where the U.S. Constitution bestows a
specific authority on a designated body, that power cannot be taken away absent a
clear statement. See, e.g., Edmond v. United States, 520 U.S. 651, 658 (1997) (rule
guarding President’s authority over appointments); FDA v. Brown & Williamson, 529
U.S. 120, 159–60 (2000) (major questions); Felker v. Turpin, 518 U.S. 651, 660 (1996)
(jurisdiction stripping statutes); Gregory v. Ashcroft, 501 U.S. 452, 460 (1991) (in the
federalism context, “[i]f Congress intends to alter the usual constitutional balance …,
it must make its intention to do so unmistakably clear …” (internal quotation
omitted)); Sossamon v. Texas, 563 U.S. 277, 285 (2011) (abrogation of sovereign
immunity must be “unmistakably clear”).
For example, courts require clear
statements before finding that Congress gave away its powers, see West Virginia v.
EPA, 597 U.S. 697, 723 (2022), before finding that Congress infringed the President’s
authority to remove federal officials, see Collins v. Yellen, 594 U.S. 220, 250 (2021),
or before concluding that the courts were stripped of jurisdiction, see Felker v. Turpin,
518 U.S. 651, 660–61 (1996).
In the same way, in reading the Missouri Constitution’s referendum
provisions, Mo. Const. art. III, §§ 49, 52(a), 52(b), courts cannot presume a major
reordering of the delicate balances struck by the framers of the Elections Clause, U.S.
Const. art. I, § 4. Just as all other parts of American government are protected by
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clear statement rules before courts find their power stripped, state legislatures are
treated no differently under the Elections Clause. See, e.g., United States v. Gradwell,
243 U.S. 476, 485 (1917) (Congress may abrogate a state legislature’s Elections
Clause authority only “by positive and clear statutes”); United States v. Oregon, 828
F. Supp. 3d 1092, 1095–96 (D. Or. 2026) (same, citing Gradwell, 243 U.S. at 485);
United States v. Caldwell, No. CV 26-2025 (ZNQ) (JTQ), 2026 WL 2186515, at *3
(D.N.J. July 29, 2026) (same, citing Gradwell, 243 U.S. at 485); see also Carson v.
Simon, 978 F.3d 1051, 1059–60 (8th Cir. 2020) (“By its plain terms, the Electors
Clause vests the power to determine the manner of selecting electors exclusively in
the ‘Legislature’ of each state,” and this power is not divested “by means of a general
statute in the [state] election code.”).
United States v. Gradwell, 243 U.S. 476, is instructive. That case involved
federal prosecutions of defendants in Rhode Island and West Virginia for election
fraud. Id. at 477–78. In Rhode Island, fourteen defendants had bribed voters during
the congressional election in 1914. Id. at 478. In West Virginia, twenty defendants
participated in an extensive conspiracy to influence a U.S. Senate election in 1916.
Id. The defendants incited and facilitated voting by “a large number of persons who
had not resided in the state a sufficient length of time to entitle them to vote under
the state law.” Id. The defendants also procured 400 of these individuals “to vote
more than once.” Id.
The United States indicted these thirty-four defendants under the U.S.
Criminal Code, citing statutes with general language that were facially broad enough
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prohibit the plainly unlawful acts of the defendants. Id. at 478–79. Specifically, the
Rhode Island defendants were indicted on “the charge that the defendants conspired
‘to defraud the United States,’ in violation of § 37 of the [federal] Criminal Code.” Id.
at 479. Section 37 contained broad language prohibiting conspiracy “to defraud the
United States in any manner for any purpose.” Id. (quoting U.S. Criminal Code § 37)
(emphasis added). The West Virginia defendants were likewise indicted on “the
charge that three candidates for the nomination for Senator of the United States were
‘injured and oppressed,’ within the meaning of § 19 of the [U.S.] Criminal Code, by a
conspiracy on the part of the defendants to compass their defeat by causing illegal
voting for an opposing party candidate at the primary election.” Id. Section 19
prohibited conspiracy “to injure, oppress, threaten, or intimidate any citizen in the
free exercise of enjoyment of any right or privilege secured to him by the Constitution
or laws of the United States, or because of his having so exercised the same …” Id.
at 479–80 (quoting U.S. Criminal Code § 19) (emphasis added).
Despite the broad language of Sections 37 and 19, federal district courts in
Rhode Island and West Virginia both dismissed the indictments. Id. at 479. The
courts held that the indictments “fail[ed] to set forth any offense under the laws of
the United States.” Id. at 479.
On appeal, the U.S. Supreme Court affirmed in an opinion applying the
Elections Clause’s clear statement rule. See id. at 480–89. In interpreting Sections
37 and 19, the Court’s opinion begins with the premise that the Elections Clause
presumptively vests regulatory authority over elections “in each state by the
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legislature thereof.”
Gradwell, 243 U.S. at 482 (quoting U.S. Const. art. I, § 4)
(emphasis added). The Court then surveyed the history of the Elections Clause since
the founding, noting Congress’s extremely limited intrusions on the authority
presumptively vested in state legislatures. Id. at 482–85; see also id. at 484 (quoting
James Madison’s prediction that the authority of “state legislatures” to regulate
elections “will probably never” be impinged).
The Court also emphasized that
whenever Congress has displaced state legislative authority, “it has done so by
positive and clear statutes”—such as election laws in effect from 1870 until 1894. See
id. at 483–85 (emphasis added).
Comparatively, Section 37’s broad language—
prohibiting “defraud[ing] the United States in any manner for any purpose,” id. at
479—was still not a “positive and clear” statement because its text did not explicitly
reference election fraud, id. at 485.
The Court also adopted a strict reading of Section 19, finding no application to
fraud and repeat voting in West Virginia’s primary election. Id. at 486–89. The Court
explained that Congress, through Section 19, “has shown no disposition to assume
control of such primaries or to participate in them in any way, and that it is not for
the courts, in the absence of such legislation, to attempt to supply it by stretching old
statutes to new uses, to which they are not adapted and for which they were not
intended.” Id. at 488–89. The Supreme Court then affirmed dismissal of all the
indictments. Id. at 489.
In light of Gradwell, multiple courts—even just this year—have invoked the
Elections Clause’s clear statement rule. See, e.g., United States v. Oregon, 828 F.
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Supp. 3d at 1095–96; United States v. Caldwell, 2026 WL 2186515, at *3. This case
is even easier than Gradwell. Gradwell dealt with Congress’s authority—expressly
vested by the Elections Clause—to “at any time by Law make or alter such [Election]
Regulations” “prescribed in each State by the Legislature thereof.” U.S. Const. art.
I, § 4. If Congress—the body with textual authority to override state legislatures
under the Elections Clause—must act with clear statements, then so too must other
actors.
This is observed in other cases involving state-level alterations to the
Elections Clause’s assignment of powers. For example, in State of Ohio ex rel. Davis
v. Hildebrandt, a “conclusive” decision by the state supreme court “ma[d]e[] it clear
that ... the referendum constituted a part of the state Constitution and laws.” 241
U.S. 565, 568 (1916). Likewise, in Arizona State Legislature v. Arizona Independent
Redistricting Commission (“AIRC”), Arizonians had specifically “amended the
Arizona Constitution to remove congressional redistricting authority from the State
Legislature.” 576 U.S., 787, 796–97 (2015).
Assuming that the Elections Clause “does not preclude” a State from
delegating redistricting authority to a referendum, changes to Elections Clause
authority must at least be specific to “safeguard limits imposed by the Federal
Constitution.” Moore v. Harper, 600 U.S. 1, 25, 35 (2023). The U.S. Constitution’s
framers made “a deliberate choice” to vest redistricting power in state legislatures,
and this Court cannot permit the vagaries of broad language in state law to transfer
that power in ways that the framers of state law did not intend. Id. at 34. The
Elections Clause requires “positive and clear” statements to displace state legislative
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authority, and it forbids “stretching old statutes to new uses, to which they are not
adapted and for which they were not intended.” Gradwell, 243 U.S. at 485, 488–89.
B.
The Missouri Constitution contains no clear statement divesting
the General Assembly of redistricting authority.
Although the Elections Clause requires a “positive and clear” statement to
divest the General Assembly of its redistricting authority, Gradwell, 243 U.S. at 485,
no such clear statement exists in the Missouri Constitution or Missouri law. “Article
III, section 45 is the only provision of the Missouri Constitution directly addressing
congressional redistricting.” Luther, 730 S.W.3d at 571. And Article III, Section 45
contemplates only that “the general assembly shall by law divide the state into
[congressional] districts.” Mo. Const. art. III, § 45 (emphasis added).
Also, the
Missouri Supreme Court has never endorsed referenda on congressional maps. See
Maggard v. State, 733 S.W.3d 411, 414 n.7 (Mo. banc 2026). Instead, the Court has
repeatedly affirmed the General Assembly’s “plenary legislative power” to redistrict
under Article III, Section 1 and Article III, Section 45. Luther, 730 S.W.3d at 571–
74. Moreover, none of the Missouri Constitution’s referendum provisions mentions
election laws or congressional redistricting. See Mo. Const. art. III, §§ 49, 52(a), 52(b).
To be sure, the language of Article III, Section 49 is broad, “reserv[ing] power
to approve or reject by referendum any act of the general assembly.” Mo. Const. art.
III, § 49. But broad language—including the word “any”—is insufficient to overcome
a clear statement rule. See Gradwell, 243 U.S. at 479–90; Ali v. Fed. Bureau of
Prisons, 552 U.S. 214, 221 n.4 (2008) (noting that clear statement rules “may
counteract the effect of expansive modifiers,” such as terms like “any” and “all civil
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actions”) (collecting cases); see also State v. Liberty, 370 S.W.3d 537, 548 (Mo. banc
2012) (adopting a narrow reading of “any” because the term was “ambiguous”).
In Gradwell, for example, Section 37 of the U.S. Criminal Code prohibited
conspiracy “to defraud the United States in any manner for any purpose.” 243 U.S.
at 479 (quoting U.S. Criminal Code § 37) (emphasis added). Yet despite the broad
language in Section 37, the U.S. Supreme Court applied the Elections Clause’s clear
statement rule, and held that “it would be a strained and unreasonable construction
to apply” Section 37 to election fraud. Id. at 485; see also id. at 489–90 (“[I]t is not for
the courts, in the absence of such legislation, to attempt to supply [election
regulations] by stretching old statutes to new uses, to which they are not adapted and
for which they were not intended.”). Likewise, Article III, Section 49’s use of the word
“any” cannot serve as a “positive and clear” statement sufficient to rip redistricting
authority away from the General Assembly. Gradwell, 243 U.S. at 485.
Unsurprisingly, since the Missouri Constitution was ratified in 1945, no court
has endorsed a referendum challenging a congressional map. One group sought a
referendum on a congressional map in 1952, but its referendum petition was
discarded because the group’s petition lacked sufficient signatures in any event. See
State ex rel. Moore v. Toberman, 250 S.W.2d 701, 702 (Mo. banc 1952). There, the
Missouri Supreme Court affirmed a circuit court judgment that “[t]he filing of
petitions for referendum prior to April 24, 1952, which said petitions have been
proved to be legally insufficient, did not suspend the effective date of” Missouri’s
congressional map. Id. at 703, 707. Then, most recently in Maggard v. State, the
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Missouri Supreme Court underscored that its opinion should not be understood to
endorse referenda against congressional maps. See 733 S.W.3d at 414 n.7 (“[T]his
opinion presupposes without deciding HB 1 is subject to the right of referendum.”).
Maggard went out of its way to note this point even though “[n]o party contend[ed]”
that HB 1 was “excepted from the right of referendum.” Id. Thus, the Missouri
Supreme Court has never endorsed referenda against congressional maps, cementing
the absence of a clear statement.7
What’s more, the 1945 Constitution explicitly abrogated the only Missouri
Supreme Court decision that has ever approved of a referendum on legislative
redistricting of any kind. See Mo. Const. art. III, § 7. In State ex rel. Gordon v. Becker,
49 S.W.2d 146 (Mo. banc 1932), the Missouri Supreme Court—in a fractured
decision—held that referenda could be used to challenge legislative districting for the
Missouri Senate. To reverse this decision, the 1943–1944 Constitutional Convention
included language in Article III, Section 7 providing that “[n]o redistricting plan shall
be subject to the referendum.” Mo. Const. art. III, § 7 (1945). The delegates at the
Missouri Constitutional Convention specifically cited the Gordon decision as
warranting adoption of the amendments to prohibit such referenda. See Debates of
the 1943–1944 Constitutional Convention of Missouri 7016 (2008). The Convention
7 Plaintiff will undoubtedly cite unreasoned dicta from Preisler v. Hearnes, 362
S.W.2d 552, 557 (Mo. banc 1962). But “an unexplained aside” in an opinion is entitled
to little weight. See Kisor v. Wilkie, 588 U.S. 558, 597–98 (2019) (Gorsuch, J.,
concurring). And Maggard vitiated any persuasive value that Preisler holds by
expressly noting that the availability of referenda on congressional maps is an open
question. See Maggard, 733 S.W.3d at 414 n.7.
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thus ensured that legislative districting for the Missouri Senate conformed with all
other legislative districting. And because the Missouri Supreme Court had never
upheld the referendum’s use for congressional redistricting, the Convention had no
need to address referenda in the context of congressional redistricting.
It is also obvious that the General Assembly has never contemplated a
referendum on a congressional map since the enactment of Chapter 116, RSMo.
Chapter 116 was enacted in 1980, and it is the General Assembly’s “framework for
exercising the right of referendum” in Missouri. No Bans on Choice v. Ashcroft, 638
S.W.3d 484, 487 (Mo. banc 2022); Maggard, 733 S.W.3d at 415–16 (“The General
Assembly enacted the statutory initiative and referendum certification process in
chapter 116 in 1980 … after then secretary of state, James Kirkpatrick, proposed a
statutory certification process.”). Chapter 116 establishes detailed procedures for
referenda and ballot initiatives. But those procedures are obviously incompatible
with referenda on congressional maps.
For example, Chapter 116 limits a referendum’s summary statement to just
100 words. § 116.334, RSMo. Chapter 116 also contains no provision for photographs
to accompany a summary statement. See § 116.334, RSMo. Redistricting is an
enormously complicated endeavor—where legislators consider legal issues like
compactness, geography, population, communities of interest, and countless other
factors. See Healey, 732 S.W.3d at 839–52. Because redistricting takes expertise, the
line-drawing power in other States is consistently vested in state legislatures or
plainly transferred to expert commissions. See Ariz. Indep. Redistricting Comm’n, 576
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U.S. at 798. If the General Assembly had the slightest inkling that Chapter 116
would facilitate referenda and initiatives on congressional maps, it would not force
average people to consider competing maps with virtually no information. In von
Glahn’s world, most voters would select a competing congressional map without
viewing either of the maps at issue. They could not possibly know—to give just one
obvious example—where counties would be placed under the competing maps. Voters
would not even know which districts they would be placed in under the competing
maps. That is absurd.
As another example, Chapter 116 sets the presumptive deadline for the
Secretary’s certification decision on the same day as the August Primary Election.
Compare § 116.150.3, RSMo, with § 115.121.1–2, RSMo. Sometimes, Chapter 116
imposes a deadline even after the August Primary if local election authorities return
their signature verifications to the Secretary less than two weeks before the Primary.
See § 116.150.3, RSMo.8 The General Assembly would have never imposed this
timeframe if it believed that referenda on congressional maps are possible. Von
Glahn criticizes the Secretary for rendering a certification decision according to
Chapter 116’s deadline.
But the Secretary followed the law perfectly.
See
§ 116.150.3, RSMo. The problem is with von Glahn’s project, not with Chapter 116.
Chapter 116 simply illustrates the obvious: The Missouri Constitution lacks any
8 “The secretary of state shall issue a certificate pursuant to this section not
later than 5:00 p.m. on the thirteenth Tuesday prior to the general election or two
weeks after the date the election authority certifies the results of a petition
verification pursuant to subsection 2 of section 116.130, whichever is later.”
§ 116.150.3, RSMo (emphasis added).
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“positive and clear” statement authorizing referenda on congressional maps.
Gradwell, 243 U.S. at 485.
The potential harm does not end with referenda. The Missouri Constitution
provides for initiative measures in the same provision where it provides for referenda.
See Mo. Const. art. III, § 49. So if a referendum were permitted, virtually any group
could use the initiative process to propose congressional maps. This could lead to a
host of consequences, including inviting violations of the “one person, one vote” rule,
see Wesberry v. Sanders, 376 U.S. 1, 18 (1964), or the Voting Rights Act. In von
Glahn’s brave new world, map-drawing would be left not to deliberative and
democratically accountable legislators or given to expert independent commissions.
Instead, various special interests groups could easily force their maps before voters
through the State’s initiative process. Voters would be “educated” on the competing
maps via dark-money-funded advertising and 100-word summary statements about
each proposal. And if the General Assembly tries its hand at redistricting, darkmoney-funded groups could easily gather signatures for a referendum, thus freezing
implementation of a new map until the next election. That, in turn, will predictably
lead to apportionment paralysis and invite one-person, one-vote violations if the State
is forced to use an old map in the interim. The potential for chaos is endless—which
goes to the lack of a clear statement in the Missouri Constitution and Missouri law.
If the framers and the General Assembly had even considered the possibility that
referenda and ballot initiatives could apply to congressional redistricting, they would
have devised a different (and more sensible) system.
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Without any clear statement, von Glahn merely cites one example of a 1922
referendum on a congressional map. See Ex. 17. This referendum was held over two
decades before the 1945 Constitution, and nearly six decades before the General
Assembly enacted Chapter 116—the modern “framework for exercising the right of
referendum” in Missouri. No Bans, 638 S.W.3d at 487; Maggard, 733 S.W.3d at 415–
16. The 1922 referendum was never the subject of litigation, and no Missouri court
has ever endorsed it. Moreover, in 1922, Missouri statutory law (unlike Chapter 116
today) forbade the Secretary of State from analyzing the substantive constitutionality
of referenda. Compare State ex rel. Kemper v. Carter, 165 S.W. 773, 780 (Mo. banc
1914), with Maggard, 733 S.W.3d at 418 (“chapter 116 went into effect in January
1981” and is “a statutory process that did not exist when Kemper was decided”).9
Thus, in 1922 (unlike today), the Secretary of State had no occasion to weigh the
constitutionality of a referendum on a congressional map. The 1922 referendum thus
lacks even an implicit endorsement from any Missouri official—legislative, executive,
or judicial.
At best, the 1922 referendum shows the practice of one group of private citizens
over a century ago. Decades later, a new Missouri Constitution was adopted in 1945.
And notably, no congressional plan has subsequently been subjected to a referendum
vote—a fact that should surprise the Court if Plaintiff’s legal theory is right, given
9 Accord von Glahn, 2025 WL 3514277, at *1, 4 n.4 (recognizing the Chapter
116 “authority” of the “Secretary of State to reject [PNP’s] petition as unconstitutional
during post-submission review”); Missouri Gen. Assembly v. von Glahn, No. 4:25-CV1535-ZMB, 2026 WL 1290477, at *4 (E.D. Mo. May 11, 2026) (same).
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the strong incentives of the minority party to challenge redistricting plans adopted
by the majority party.
Thus, the 1922 example is hardly a line of established,
unbroken practice about the meaning of the Missouri Constitution’s referendum
provisions. Moreover, even if such practice existed, it would not be sufficient to
overcome the Elections Clause’s clear statement rule. See Armstrong v. Exceptional
Child Ctr., Inc., 575 U.S. 320, 329 (2015) (even “long-established practice” cannot
overcome a clear statement rule); Mejia Olalde v. Noem, No. 1:25-CV-00168-JMD,
2025 WL 3131942, at *5 (E.D. Mo. Nov. 10, 2025) (same).
Von Glahn has thus failed to provide a “positive and clear” statement in the
Missouri Constitution authorizing referenda on congressional maps. Gradwell, 243
U.S. at 485.
C.
Even read without reference to the U.S. Constitution’s Elections
Clause, the Missouri Constitution does not authorize referenda
on congressional maps.
Even if the Elections Clause did not impose a clear statement rule (it does), the
Missouri Constitution—properly read—does not sanction referenda on congressional
maps. “Article III, section 45 is the only provision of the Missouri Constitution
directly addressing congressional redistricting.” Luther, 730 S.W.3d at 571. And
Article III, Section 45 provides that after “each census,” “the general assembly shall
by law divide the state into districts corresponding with the number of
representatives to which it is entitled.” Mo. Const. art. III, § 45 (emphasis added).
In other words, Section 45 invalidates the pre-Census map and obligates the General
Assembly to redistrict after each decennial Census. Section 45 also makes no mention
of a referendum being available for congressional redistricting plans. This is for good
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reason: If the Missouri Constitution’s referendum provisions apply to redistricting,
fulfilling the General Assembly’s duty under Article III, Section 45 could be
impossible—and Missouri could be left with no congressional map after the decennial
Census.
The Court must also keep in mind that all “[c]onstitutional limitations on the
legislative power are ‘strictly construed in favor of the power of the General
Assembly.’” Luther, 730 S.W.3d at 571 (quoting Bd. of Educ. of City of St. Louis, 879
S.W.2d at 533).
And “the General Assembly has the power to do whatever is
necessary to perform its functions except as expressly restrained by the Constitution.”
Id. (emphasis added) (quoting Liberty Oil, 813 S.W.2d at 297). In light of these
standards, Article III, Section 45 makes this a straightforward case. Section 45
expressly obligates the General Assembly to use its legislative powers to redistrict.
Luther, 730 S.W.3d at 571–73. Thus, the Missouri Constitution only bolsters the
General Assembly’s already expansive legislative power in the redistricting context.
Moreover, the referendum provision itself can be read to exempt congressional
maps from its coverage. Maggard, 733 S.W.3d at 414 n.7. Article III, Section 52(a)
specifically excepts from the referendum “laws necessary for the immediate
preservation of the public peace, health or safety, and laws making appropriations for
the current expenses of the state government, for the maintenance of state institutions
and for the support of public schools.” Mo. Const. art. III, § 52(a) (emphasis added).
Any apparent conflict in the Constitution could be harmonized through at least two
of these exceptions. See State ex rel. Jones v. Atterbury, 300 S.W.2d 806, 810 (Mo.
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banc 1957) (“The constitution must be read as a whole and seemingly conflicting
provisions should be harmonized so as to give effect to the whole.” (citing Toberman,
250 S.W.2d at 705)).
First, congressional maps are excepted from referenda because they are
necessary “for the maintenance of state institutions.” Mo. Const. art. III, § 52(a). The
term “institution” can refer to “a custom or practice that has existed for a long time
and is accepted as an important part of a society,” such as “the institution of
marriage.”
Institution, CAMBRIDGE DICTIONARY;10 see also Institution, MERRIAM
WEBSTER DICTIONARY (similar).11
Laws necessary “for the maintenance of state
institutions,” Mo. Const. art. III, § 52(a), can thus refer to laws necessary to preserve
the most basic norms and practices of Missouri. That principle applies here because
suffrage is certainly a fundamental Missouri institution. See Mo. Const. art. I, § 25;
Priorities USA v. State, 591 S.W.3d 448, 452 (Mo. banc 2020). “The right to vote freely
for the candidate of one’s choice is of the essence of a democratic society.” St. Louis
Cnty. Bd. of Election Commissioners v. McShane, 492 S.W.3d 177, 180 (Mo. App. E.D.
2016) (internal quotation omitted).
The U.S. Constitution also guards the
fundamental right of Missourians to select their representatives in Congress every
two years. U.S. Const. art. I, § 2.
Perhaps no institution could be more fundamental to a free society than
elections. To maintain that State institution, the Missouri Constitution specifically
10https://dictionary.cambridge.org/dictionary/english/institution?q=Institution
11 https://www.merriam-webster.com/dictionary/institution
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obligates the General Assembly to redistrict (at least) after each Census. Mo. Const.
art. III, § 45. The General Assembly also holds plenary legislative authority to
redistrict even more often if necessary. See Luther, 730 S.W.3d at 571–74. PostCensus redistricting is also functionally required by virtue of the U.S. Constitution’s
“one person, one vote” rule. See Wesberry, 376 U.S. at 18. “Legislators are elected by
voters, not farms or cities or economic interests. As long as ours is a representative
form of government, and our legislatures are those instruments of government
elected directly by and directly representative of the people …” Reynolds v. Sims, 377
U.S. 533, 562 (1964). Fulfilling these requirements would be impossible without
redistricting. See Mo. Const. art. III, § 45. Thus, redistricting legislation is squarely
excepted from referenda because it is necessary “for the maintenance” of suffrage—
which is a fundamental “state institution[].” Id. art. III, § 52(a).
Second, redistricting legislation is excepted from the referendum because it is
“necessary” for “preservation of the public peace, health or safety.” Mo. Const. art.
III, § 52(a).
Again, facilitating elections is impossible without redistricting
legislation. And “the political franchise of voting” is “preservative of all rights.”
Harper v. Virginia State Bd. of Elections, 383 U.S. 663, 667 (1966) (quoting Yick Wo
v. Hopkins, 118 U.S. 356, 370 (1886)). That is why the Missouri Constitution speaks
“‘with unmistakable clarity’ that Missouri citizens have a fundamental right to vote.”
Priorities USA, 591 S.W.3d at 452 (citation omitted); Mo. Const. art. I, § 25 (“[A]ll
elections shall be free and open; and no power, civil or military, shall at any time
interfere to prevent the free exercise of the right of suffrage.”). Regular and fair
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elections are a fundamental component of a free society. Article III, Section 52(a)
thus exempts election laws, such as the HB 1 map, from referendum challenges.
Miniscule fractions of Missouri’s population (3.3% of voters) cannot demand referenda
on legislation that is so essential to the “preservation of the public peace.” Mo. Const.
art. III, § 52(a).
The Court should therefore conclude that the Missouri Constitution does not
authorize referenda against congressional maps and enter judgment for the
Secretary.
II.
The U.S. Constitution renders Article III, Section 52(b) of Missouri
Constitution invalid as applied to HB 1.
In the alternative, even if the Court believes that the Missouri Constitution
permits referenda on congressional maps, the U.S. Constitution would invalidate
Article III, Section 52(b)—which freezes referred laws pending a statewide vote—as
applied to HB 1. And, in the event of a conflict, the U.S. Constitution supersedes.
See U.S. Const. art. VI (“This Constitution, and the Laws of the United States … shall
be the supreme Law of the Land … any Thing in the Constitution or Laws of any
State to the Contrary notwithstanding.”); Mo. Const. art. I, § 4 (“Missouri is a free
and independent state, subject only to the Constitution of the United States”).
Two provisions of the U.S. Constitution are relevant. First, the Elections
Clause provides that “[t]he Times, Places and Manner of holding Elections for
Senators and Representatives, shall be prescribed in each State by the Legislature
thereof.” U.S. Const. art. I, § 4. This Clause is rooted in a republican theory of
government, and it was essential to securing ratification of the U.S. Constitution.
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The founders settled on vesting regulatory authority over elections in state
legislatures—as “the representative body which ma[kes] the laws of the people.”
Smiley v. Holm, 285 U.S. 355, 365 (1932) (emphasis added, internal quotation
omitted).
But in von Glahn’s proposed world, about 3.3% of Missourians can temporarily
suspend a duly-enacted congressional map. Pet. ¶¶ 6–7, 42–43, 45; id. at 8. That
would flagrantly violates the Elections Clause. HB 1 passed overwhelmingly in both
houses of the General Assembly and was signed by the Governor. See Mo. Senate J.
25–26 (2d Extra. Sess., 103d Gen. Assembly, Sept. 12, 2025); Mo. House J. 37–38 (2d
Extra. Sess., 103d Gen. Assembly, Sept. 9, 2025). Yet according to von Glahn, the
Article III, Section 52(b) of the Missouri Constitution mandates that HB 1 cannot
take effect (and is thus temporarily repealed) until voters weigh in. See Pet. ¶¶ 6–7,
42–43, 45; id. at 8.
That would violate the U.S. Constitution and basic democratic principles. If
von Glahn is right, just 3.3% of registered voters could suspend Missouri’s
congressional map for an entire election cycle. See Mo. Const. art. III, § 52(a); Pet.
¶ 42 (von Glahn alleging that “he is entitled to the immediate suspension of the use
and implementation of HB 1”). To the extent that the U.S. Constitution’s Elections
Clause means anything, it certainly prohibits 3.3% of voters from voiding a
congressional map enacted by the General Assembly.
Of course, 110 years ago in Hildebrandt, 241 U.S. 565, the U.S. Supreme Court
held that the U.S. Constitution’s Guarantee Clause did not prevent Ohio from
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subjecting congressional maps to a referendum. But neither Hildebrant nor any other
Supreme Court decision suggested that just 3.3% of a State’s voters can displace a
lawfully-enacted congressional map for an entire election cycle. To allow that result
here would defy the Elections Clause, and would “introduce a virus which destroys
that [legislative] power, which in effect annihilates representative government.” Id.
at 569.
Such a scheme would also violate the U.S. Constitution’s Guarantee Clause.
The Guarantee Clause provides that “[t]he United States shall guarantee to every
State in this Union a Republican Form of Government.” U.S. Const. art. IV, § 4.
There is no mystery about what constitutes a “Republican Form of Government.” Id.
“All the States had governments when the Constitution was adopted. In all the
people participated to some extent, through their representatives elected in the
manner specially provided.” Minor v. Happersett, 88 U.S. 162, 175 (1874). Von
Glahn’s proposed remedy—nullification of HB 1 without a majority vote, Pet. ¶¶ 42–
43, 45; id. at 8—would allow a small, unelected fraction of Missourians to control the
State’s congressional map for an entire election cycle. This palpably affronts the
Guarantee Clause.
In George Washington’s words, “[I]f the Laws are to be so
trampled upon—with impunity—and a minority (a small one too) is to dictate to the
majority,” then “there is an end put, at one stroke, to republican government.” See
Letter from George Washington to Charles Mynn Thruston (Aug. 10, 1794).12
12 https://founders.archives.gov/documents/Washington/05-16-02-0376
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The Guarantee Clause “necessarily implies a duty on the part of the States
themselves to provide” a republican form of government. Minor, 88 U.S. at 175.
Thus, the State of Missouri cannot permit just 3.3% of the State’s voting population
to suspend a duly-enacted congressional map. See Mo. Const. art. III, §§ 52(a), 52(b).
To permit this would blatantly violate the separation of powers, which is essential to
republican government. Surely, if the legislative authority and the Governor’s veto
authority cannot be broadly delegated to “unelected administrative official[s],” then
it would violate basic republican principles to vest legislative and veto authority in a
small band of voters seeking to temporarily suspend a congressional map.
See
Robinson v. Missouri Dept. of Health and Sr. Services, No. 20AC-CC00515, 2021 WL
7441868, at *1 (Mo.Cir. Nov. 26, 2021) (Green, J.). Indeed, “[o]ne of the settled
maxims in constitutional law is that the power conferred upon the legislature to make
laws cannot be delegated by that department to any other body or authority.” Id.
(quoting Cooley, Constitutional Limitations (1886), pp. 116–117). But that is exactly
what von Glahn tries to do here.
Even “a middle school civics student would
recognize” a problem with this. Id.
History and tradition also confirm this understanding. As to history, the
founding generation clearly understood “a republic” to refer to “a government in
which the scheme of representation takes place.” Federalist No. 10 (Madison). James
Madison explained that a “republic” involves “the delegation of the government … to
a small number of citizens elected by the rest.” Id. Post-enactment tradition also
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confirms the founders’ understanding of a “Republican Form of Government.” U.S.
Const. art. IV, § 4. In Duncan v. McCall, the U.S. Supreme Court opined:
By the constitution, a republican form of government is guarantied to every
state in the Union, and the distinguishing feature of that form is the right of
the people to choose their own officers for governmental administration, and
pass their own laws in virtue of the legislative power reposed in representative
bodies, whose legitimate acts may be said to be those of the people themselves
...
139 U.S. 449, 461 (1891).
Members of the Missouri Supreme Court have also agreed that a “Republican
Form of Government” refers to the fundamental right of Missourians to enact laws
through their elected representatives. In a 1917 case, Judge Archelus Woodson
articulated this understanding clearly:
Under a republican form of government (and all of the states of the Union are
such, Section 4, art. 4, of the Constitution of the United States), I know of no
mode by which a state can put in force and operation a statute, except by the
lawmaking body thereof, and, when properly enacted, it is designated and
commonly called a statute, and, of course, is a statute of the state enacting it.
Madden v. Missouri Pac. Ry. Co., 192 S.W. 455, 458 (Mo. banc 1917) (Woodson, J.,
concurring in the judgment).
Together, these sources show that the right of the people to enact legislation
through elected representatives is the defining feature of a “Republican Form of
Government.”
U.S. Const. art. IV, § 4.
As to HB 1, Missourians have spoken
overwhelmingly. HB 1 passed 21 to 11 in the Senate and 90 to 65 in the House of
Representatives. See Mo. Senate J. 25–26 (2d Extra. Sess., 103d Gen. Assembly,
Sept. 12, 2025); Mo. House J. 37–38 (2d Extra. Sess., 103d Gen. Assembly, Sept. 9,
2025). Even if a small percentage of Missouri’s registered voters signed a referendum
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petition, Mo. Const. art. III, § 52(a), the Guarantee Clause forbids the State of
Missouri from allowing a small fraction to override the People’s elected
representatives. This is especially true in the context of a congressional map, where
this years’ election will control Missouri’s representation in Congress for the next two
years. Until a majority of Missourians vote against the HB 1 map, the will of the
People must remain in effect. Any other result would violate the Guarantee Clause.
III.
Changing the congressional map at this hour is impossible. Thus, the
Hadley-Purcell principle forbids von Glahn’s impossible demand.
Even if von Glahn is correct that 3.3% of Missouri voters can freeze duly
enacted congressional maps, changing the congressional map is “literally impossible”
after the 2026 Primary Election. Ex. 28, Brown Aff. ¶ 6. Von Glahn pretends that
the Court can award relief simply by enjoining “the use and implementation of HB 1.”
Pet. ¶¶ 42–43, 45; id. at 8. But having demanded this extraordinary remedy, von
Glahn’s Petition offers zero explanation as to how the Court can provide it. Indeed,
it is unclear whether von Glahn envisions an injunction ordering a new Primary
under the so-called “correct congressional districts,” id. ¶ 45, or whether he demands
an injunction that would simply change Missouri’s map as to the General Election
alone. In the latter case, it is unclear whether von Glahn intends to throw out the
results of the Primary Election before proceeding to the General Election under a
completely different congressional map.
No matter what von Glahn envisions, basic principles of equity mandate
rejection of von Glahn’s claims. It is far, far too late to change the map governing the
2026 elections. Candidate filing ended in late March. § 115.349.1, RSMo. Missouri
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finished its Primary Election—in which 1.2 million people voted—roughly two weeks
ago. §§ 115.121.2, 115.341, RSMo. On the date of trial, the General Election will be
less than eleven weeks away. § 115.121.1, RSMo. At this point, changing the HB 1
map is unthinkable—even if von Glahn proves a constitutional violation.
The Missouri Supreme Court’s decision in Hadley is dispositive. See Hadley v.
Junior Coll. Dist. of Metro. Kansas City, 460 S.W.2d 1 (Mo. banc 1970). There, the
Missouri Supreme Court confronted a remand after the U.S. Supreme Court found
that districts for electing school officials were unconstitutionally apportioned. 460
S.W.2d at 2. On the date that the Missouri Supreme Court rendered its decision, the
candidate filing period was scheduled to end in a few days. Id. at 2. The Court noted
that “[f]ive candidates have filed for the office, and the election machinery already is
in operation.” Id. at 3. Furthermore, “[a]bsentee ballots for that election are now
being printed and other preparations, including necessary adjustments of voting
machines, are in progress. Substantial expense has been incurred and substantial
additional expense would be involved if the election of trustees is postponed and such
election is held at a later date.” Id. The Court thus concluded that “it would be wholly
inequitable and impracticable to attempt at this late date to” order an adjustment to
the unconstitutionally apportioned districts. Id. In reaching this conclusion, the
Court noted the U.S. Supreme Court’s own precedent that “a court is entitled to and
should consider the proximity of a forthcoming election and the mechanics and
complexities of state election laws, and should act and rely upon general equitable
principles.” Id. at 2 (emphasis added) (quoting Reynolds, 377 U.S. at 585).
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Today, the U.S. Supreme Court still applies this equitable principle—known
as the Purcell principle in federal court. See Purcell v. Gonzalez, 549 U.S. 1, 4–5
(2006). In fact, the U.S. Supreme Court applied the Purcell principle to foreclose
challenges to Texas’s congressional map for the 2026 elections nine months ago—
during Texas’s candidate filing period. See Abbott v. LULAC, 146 S. Ct. 418, 419
(2025). If this case were in federal court, von Glahn’s request for an injunction would
be deemed frivolous.
Undeterred, von Glahn soldiers on—demanding a change to Missouri’s
congressional map two weeks after the August Primary. The State is not aware of
any court that has ever awarded such a drastic remedy.
requires rejection of von Glahn’s claims here.
And Hadley certainly
Missouri’s candidate-filing period
closed over four months ago. § 115.349.1, RSMo. The Primary Election finished over
a week ago. §§ 115.121.2, 115.341, RSMo. For almost a year, candidates have built
their campaigns based on the assumption that the HB 1 map would govern. Money
has been raised; voters have adjusted to new districts; and 1.2 million Missourians
voted under those districts. Candidates are now campaigning for Missouri’s General
Election in November.
Candidates advancing to the General Election have
collectively raised about $20,000,000 for the contest in November.13 Candidates and
13 See Fed. Elec. Comm’n, Campaign Finance Data: Missouri - House District
01, https://archive.is/6vnQU; id. Missouri - House District 02, https://archive.is/e7DxI;
id. Missouri - House District 03, https://archive.is/Dx3FE; id. Missouri - House
District 04, https://archive.is/WLaJ7; id. Missouri - House District 05, https://
archive.is/D5YSa; id. Missouri - House District 06, https://archive.is/HuVvv; id.
Missouri - House District 07, https://archive.is/Sveh3; id. Missouri - House District 08,
https://archive.ph/HzSmW.
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voters have overwhelming reliance interests in maintaining the current map. See Ex.
35; Ex. 36; Ex. 37; Merrill v. Milligan, 142 S. Ct. 879, 880–81 (2022) (Kavanaugh, J.,
concurring) (“Late judicial tinkering with election laws can lead to disruption and to
unanticipated and unfair consequences for candidates, political parties, and voters,
among others.”).
Also, changing the map before the General Election is “literally impossible”—
as Tammy Brown’s testimony establishes. Ex. 28, Brown Aff. ¶¶ 6, 19. Brown has
twenty-five years of experience as a Jackson County election official. Id. ¶ 1. She has
facilitated over a hundred elections in Jackson County, and she helped manage
Jackson County’s efforts to implement redrawn congressional maps in 2012, 2022,
and 2026. Id. ¶¶ 1, 3. Brown has never heard of Missouri—or any other State—ever
changing their congressional map between a primary election and a general election.
Id. ¶ 5.
As Brown explains in her affidavit, to implement a new congressional map,
local election officials must transfer voters in Missouri’s Centralized Voter
Registration (“MCVR”) system. This is a slow, meticulous process that involves
manually moving individual voters from one congressional district to another. Id.
¶ 7. It involves careful analysis of printed maps, and several rounds of proofreading.
Id. This arduous process usually takes 2 – 2 ½ weeks, and requires at least 7–10 days
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if election officials worked overtime and weekends in order to quickly implement a
new map. Id.14
Critically, the MCVR system locks shortly before absentee ballots are
distributed and remains locked until an election is certified two weeks after election
day. Id. ¶ 8.15 This year, the MCVR system will remain locked until (at least) midNovember because of a Jackson County special election in September 2026. Id. ¶ 9.
Thus, changing the map in the MCVR system is “literally impossible” until after the
November General Election. Id. ¶¶ 6, 19.16
14 Accord Ex. 32, Letter of Missouri Association of County Clerks and Election
Authorities; Ex. 29, Amicus Br. of Brianna Lennon at 11–14, supra; Ex. 30, Amicus
Br. of Kurt Bahr at 13–16, supra; Ex. 31, Trial Testimony of Shawn Kieffer at 109:1–
17, supra.
15 In light of MCVR’s locking function, the Missouri Association of County
Clerks and Election Authorities feared that there would not be any window available
after January 2026 to change Missouri’s congressional map. See Ex. 32, Letter of
Missouri Association of County Clerks and Election Authorities (“Redistricting
complicates this process because MCVR ‘locks’ current district boundaries during any
active election so that new districts cannot be created, and voters subsequently
cannot be assigned to new districts.”); see also Ex. 29, Amicus Br. of Brianna Lennon
at 11–14, supra (“Typically, the last possible time for a local election official to
establish new districts for an election is the ninth Tuesday before an election.”);
Ex. 30, Amicus Br. of Kurt Bahr at 13–16, supra (“[L]ocal election authorities cannot
access MCVR to enter new district lines at just any time of year. For lengthy
stretches of time, MCVR is necessarily ‘locked’ to protect against structural
districting changes. This lockout lasts for a period before and after each election while
ballots are printed and mailed, poll lists are compiled, voting occurs, votes are
canvassed, and returns are certified.”).
Brown also address the affidavit of Brianna Lennon, explaining: “Ms.
Lennon’s representation is wrong [at least] as to Jackson County. In Jackson County,
we exclusively implemented the HB 1 congressional map in the MCVR database for
the 2026 congressional election. Reverting to the 2022 map would require us to
reopen the MCVR database and to manually adjust each precinct’s and each voter’s
16
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Further, to comply with UOCAVA, Missouri local election officials must send
ballots to military and overseas voters no later than September 19, 2026. See 52
U.S.C. § 20302(a)(8). This requires printing ballots no later than eight weeks before
the election (September 8, 2026). Ex. 28, Brown Aff. ¶ 11. Election officials also need
at least two weeks before printing (August 25, 2026) to design and test ballots. Id.17
And all of this can occur only after Missouri election officials implement the
congressional map in the MCVR database.
Id.18
But again, changing the
congressional map in MCVR is impossible while an election is ongoing. Id. ¶ 8.19 And
Missouri currently has several ongoing elections—between the August Primary
Election and the September Special Election in Jackson County. Id. ¶ 9.
In other words, von Glahn’s proposed remedy is impossible. Von Glahn surely
knows this.
That is why, many months ago, PNP and von Glahn repeatedly
characterized their lawsuits as “time-sensitive election case[s]” because of their
“impact” on “the 2026 election” and the need to avoid “chaos in August.” Ex. 22, Mot.
congressional district back to the 2022 map. As far as I am aware, there is no ‘magic
button’ that would suddenly allow us to revert to the 2022 congressional districts.”
17 Accord Ex. 31, Trial Testimony of Shawn Kieffer at 105:25–108:21.
18 Accord Ex. 32, Letter of Missouri Association of County Clerks and Election
Authorities (“The lack of decided boundary lines [implemented in MCVR] effectively
prohibits election authorities from preparing ballot types that accurately represent
the correct political subdivisions for each residential address, which means ballots
will not be ready for voters.”).
19 Accord Ex. 32, Letter of Missouri Association of County Clerks and Election
Authorities; Ex. 29, Amicus Br. of Brianna Lennon at 11–14, supra; Ex. 30, Amicus
Br. of Kurt Bahr at 13–16, supra.
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to Expedite at 1–2, State ex rel. People Not Politicians v. Limbaugh, No. WD88821
(Mo. App. W.D., filed April 1, 2026); see also Ex. 23, SIS Pet. for Writ of Prohibition
at 5–6, Limbaugh, No. WD88821. That is also why opponents of HB 1—including
opponents represented by von Glahn’s counsel—repeatedly stated that they needed
judicial resolution of HB 1’s status before the candidate-filing period opened last
February.20 Many of these plaintiffs acknowledged that equitable principles would
eventually require Missouri courts “to favor the status quo in a legal dispute during
the lead-up to an election.” See, e.g., Ex. 26, SIS Mot. for Prelim. Inj. at 16, Maggard
v. State, No. 25AC-CC09120 (Mo. Cir. Ct., filed Jan. 14, 2026) (quotation omitted).
The State never contested that point; in fact, it started asserting the Hadley-Purcell
principle in February 2026. See Respondent’s Br. at 54, Luther v. Hoskins, No.
SC101412 (Mo., filed Feb. 9, 2026). And even Democracy Docket admitted in March
2026 that Judge Stumpe’s ruling in Maggard “likely killed attempts to stop
Republicans from imposing the new map” because of the candidate-filing deadline
“rapidly approaching on Mar. 31,” 2026. Ex. 34, Jen Rice, GOP derails bid to stop
Missouri gerrymander for 2026, Democracy Docket (Mar. 27, 2026).21 Now, two weeks
after the Primary Election, it is certainly too late to enjoin “any further steps to
implement or mandate the use of HB 1.” Pet. at 8.
20 See Ex. 24, Mot. to Expedite at 2, Luther v. Hoskins, No. SC101412 (Mo.
banc, filed Dec. 31, 2025); Ex. 25, Pltfs.’ Opp. to a Continuance at 1–3, Wise v. State
and Healey v. State, Nos. 2516-CV29597, 2516-CV31273 (Mo. Cir. Ct., filed Dec. 15,
2025); Ex. 26, SIS Mot. for Prelim. Inj. at 16, Maggard v. State, No. 25AC-CC09120
(Mo. Cir. Ct., filed Jan. 14, 2026).
21 https://archive.ph/pUnQs
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Other cases also corroborate why Missouri must conduct its general election
under the HB 1 map. As far as the State is aware, every time a redistricting plan is
invalidated after a primary election, courts have stayed their remedy as to the
upcoming general election. See, e.g., Covington v. North Carolina, 316 F.R.D. 117,
176–77 (M.D.N.C. 2016) (allowing general election “to proceed as scheduled under the
challenged plans” despite being determined unconstitutional after the primary); Page
v. Va. State Bd. of Elections, 58 F. Supp. 3d 533, 554 (E.D. Va. 2014) (“[G]eneral
principles of equity dictate that Virginia’s 2014 elections should proceed as scheduled
under the challenged districting plans” after plan found invalid one month before
general election.), vacated on other grounds sub nom., Cantor v. Personhuballah, 135
S. Ct. 1699 (2015); Vera v. Richards, 861 F. Supp. 1304, 1351 (S.D. Tex. 1994)
(ordering election held on unconstitutional map after primary had already been held),
aff’d sub nom., Bush v. Vera, 517 U.S. 952 (1996); see also Terrazas v. Slagle, 821 F.
Supp. 1154, 1159 (W.D. Tex. 1992) (“Primary elections for offices chosen by the
electorate in separate geographical districts obviously make no sense unless the
districts are the same for the ensuing general election as for the primary.”). This
Court must similarly reject von Glahn’s request for such a drastic remedy here.
IV.
The U.S. Constitution and federal law forbid changing Missouri’s
congressional map during an election.
Finally, von Glahn’s proposed remedy—an injunction against “the use and
implementation of HB 1,” Pet. ¶¶ 42–43, 45; id. at 8—would violate the U.S.
Constitution and federal law.
It is unclear precisely what remedy von Glahn
envisions, especially because the Primary Election finished on August 4.
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regardless, any potential remedy would violate federal law and the U.S. Constitution.
Hosting another primary would be impossible in light of deadlines prescribed by
UOCAVA, 52 U.S.C. § 20302. And holding a General Election under a different
congressional map would violate the U.S. Constitution’s Article I, Section 2 and its
Equal Protection Clause. Thus, the Court must reject von Glahn’s proposed remedy.
A.
An order requiring the State to host a new Primary Election
would force a violation of 52 U.S.C. § 20302 (“UOCAVA”).
Von Glahn’s first potential remedy—an order invalidating the Primary
Election altogether and requiring a new primary—would force Missouri to violate
UOCAVA, 52 U.S.C. § 20302.
UOCAVA requires local election authorities to transmit ballots “not later than
45 days before the election” to military and overseas voters, 52 U.S.C. § 20302(a)(8),
§ 115.914, RSMo, and Missouri statutes implementing UOCAVA prevent the
certification of election results for three days after an election, see §§ 115.920.1,
115.508, RSMo. Mathematically, that requires at least 93 days to run a primary and
general election by the federally-imposed deadline on November 3, 2026. See Foster
v. Love, 522 U.S. 67, 73–74 (1997) (holding that State may not run federal election in
conflict with federal timing of 2 U.S.C. § 7). Yet, on the day of trial, Missouri will be
76 days away from the November General Election. Thus, as a matter of federal law,
it is already too late to order Missouri to re-run its Primary Election.
UOCAVA is also enforceable by the U.S. Attorney General in federal district
court. 52 U.S.C. § 20307(a). Any failure to comply with UOCAVA by Missouri would
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likely subject the State to an adverse federal injunction contradicting any potential
state order that conflicts with UOCAVA. See id.
The Court should comply with federal law and reject von Glahn’s claim.
B.
An order requiring a General Election under a different map
would violate the U.S. Constitution.
To the press, Plaintiff’s counsel has floated an alternative proposal: having the
winners of the Primary Election held under the HB 1 map simply run in different
congressional districts in the General Election. See, e.g., Jason Hancock, Referendum
campaign asks court to block new Missouri map from November election, MISSOURI
INDEPENDENT (Aug. 5, 2026);22 see also Pet. ¶ 45.
In other words, hundreds of
thousands of voters would vote for candidates in the General Election that they had
no role in choosing in the Primary Election. Cole County voters, for example, chose
Rick Brattin and Emanuel Cleaver as the candidates for Congressional District 5, but
Plaintiff apparently thinks Cole County voters should be forced to choose between
Bob Onder and Bethany Mann—who were chosen by entirely different voters in
Congressional District 3.
This idea is not just profoundly antidemocratic; it violates federal law. The
U.S. Constitution protects the right to vote and prohibits States from nullifying votes
cast in federal congressional elections. See U.S. Const. art. I, §2; United States v.
Mosley, 238 U.S. 383, 386 (1915) (recognizing that the constitutional right to vote
includes “right to have one’s vote counted”). But that is exactly what von Glahn
22 https://archive.is/Sb26p
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seemingly proposes here—a plan that would render hundreds of thousands of votes
in the Primary Election effectively null and void.
Nor does the fact that von Glahn proposes to nullify a primary election—as
opposed to a general election—change anything. U.S. Supreme Court precedent
establishes that “[w]here the state law has made the primary an integral part of the
procedure of choice . . . the right of the elector to have his ballot counted at the
primary, is likewise included in the right protected by” the Constitution’s right to
vote. United States v. Classic, 313 U.S. 299, 318 (1941). Said another way, the
primary and general elections are “fus[ed]” into a “single instrumentality” such that
they possess a “unitary character.” Smith v. Allwright, 321 U.S. 649, 660–61 (1944).
This is certainly true in Missouri, where the State Supreme Court has held
that “[n]ominating or primary elections have constitutional stature in Missouri” and
serve an “integral part of [the State’s] election machinery.” State ex rel. McClellan v.
Kirkpatrick, 504 S.W.2d 83, 86 (Mo. banc 1974) (citing Mo. Const. art. VIII, § 3).
Missouri law also provides that “all candidates for elective office shall be nominated
at a primary election,” §§ 115.339, 115.343, RSMo. Thus, the primary “exclud[es]
from the ballot on the general election the names of candidates rejected at the
primary” such that it “impose[s] restrictions upon the choice of candidates by the
voters save by voting at the primary election.” Classic, 313 U.S. at 313. This makes
the primary “integral” “as a matter of law.” Id. at 314; McClellan, 504 S.W.2d at 86.
Von Glahn’s proposed scheme also violates the U.S. Constitution’s Equal
Protection Clause for an additional reason. See U.S. Const. amend. XIV, § 1. Once
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again, von Glahn envisions requiring hundreds of thousands of Missourians to
consider a slate of candidates that they never considered in the Primary Election.
These voters would possess less voting power than those who participated in a
Primary and General Election in the same congressional district. That disparity in
voting power would violate the Equal Protection Clause.
For example, in Gray v. Sanders, the U.S. Supreme Court confronted Georgia
primary-election procedures that “weight[ed] the rural vote more heavily than the
urban vote and weight[ed] some small rural counties heavier than other larger rural
counties.” Gray v. Sanders, 372 U.S. 368, 379 (1963). The Court held that this
disparity violated the Equal Protection Clause, explaining: “Once the geographical
unit for which a representative is to be chosen is designated, all who participate in
the election are to have an equal vote—whatever their race, whatever their sex,
whatever their occupation, whatever their income, and wherever their home may be
in that geographical unit.” Id. (emphasis added). “This is required by the Equal
Protection Clause of the Fourteenth Amendment. The concept of ‘we the people’
under the Constitution visualizes no preferred class of voters but equality among
those who meet the basic qualifications.” Id. at 379–80.
The remedy that von Glahn suggests—changing the congressional map in the
middle of an election—would flagrantly violate this standard. It would diminish the
voice of many Missourians (including every voter in Cole County) who would be forced
to vote for different slates of candidates in the Primary and General Elections. This
would be particularly problematic in districts where primaries are more competitive
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than the general election. In those districts, the primary election is the contest where
voters effectively select their representative.
Thus, even if a referendum on HB 1 is constitutional, the General Election
must go forward under the existing map. The Primary Election is now complete. And
because “this right of participation [in the Primary Election] is protected just as is
the right to vote at the [General] election,” Classic, 313 U.S. at 318, invalidating the
Primary Election result would undermine the voters’ “ultimate choice of the
representative” under Article I, Section 2 of the U.S. Constitution, id.23
*
*
*
In seeking an injunction against HB 1 before the General Election, von Glahn
appears naïve about the blast radius of his demand. Regardless of how the Court
23 Von Glahn could theoretically argue at trial that Missouri’s political parties could
simply nominate new candidates to run in a General Election with different
congressional map. But nothing in Missouri law allows this Court to throw out 1.2
million votes cast in the completed Primary Election. Indeed Section 115.343
provides:
The person receiving the greatest number of votes at a primary election
as a party candidate for an office shall be the only candidate of that
party for the office at the general election. The name of such candidate
shall be placed on the official ballot at the general election unless he is
removed or replaced as provided by law.
§ 115.343, RSMo (emphasis added). The law provides for removal or replacement of
the nominated candidate for only three reasons: The nominee (1) “die[s],” (2) “is
disqualified,” or (3) voluntarily “withdraw[s].” § 115.363.3(1)–(3), .4. In those three
cases, “the party nominating committee for any established political party may select
a party candidate.” Id. But here, if the HB 1 map is invalidated, none of the nominees
that voters selected would have died, disqualified themselves, or withdrawn.
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reads the Missouri Constitution, it cannot order the State to violate federal law by
using a different congressional map than the one used in the 2026 Primary Election.
CONCLUSION
For the above reasons, the Court should reject von Glahn’s claims and enter
judgment in favor of the Secretary.
Date: August 18, 2026
Respectfully submitted,
CATHERINE L. HANAWAY
ATTORNEY GENERAL
/s/ Louis J. Capozzi III
Louis J. Capozzi III, #77756
Solicitor General
J. Michael Patton, #76490
Deputy Solicitor General
Office of the Attorney General
815 Olive Street, Suite 200
St. Louis, MO 63101
Tel. (573) 645-9662
Fax (573) 751-0774
Louis.Capozzi@ago.mo.gov
Michael.Patton@ago.mo.gov
Counsel for the Secretary of State
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CERTIFICATE OF SERVICE
I hereby certify that on August 18, 2026, a true and accurate copy of the above
was electronically filed by using the Court’s CM/ECF system to be served via
operation of the Court’s electronic filing system upon all counsel of record.
Louis J. Capozzi, III
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IN THE CIRCUIT COURT OF COLE COUNTY, MISSOURI
RICHARD VON GLAHN,
Plaintiff,
v.
DENNY HOSKINS, in his official
capacity,
Defendant.
)
)
)
)
)
)
)
)
)
)
Case No. 26AC-CC00440
INTERVENORS’ TRIAL BRIEF
Plaintiff asks this Court to read silence in the Missouri Constitution as
overriding its plain text to empower a small minority of voters to nullify the
results of Missouri’s recent congressional primary elections, suspend the
General Assembly’s duly enacted congressional districting plan for the ongoing
2026 election, and unleash chaos upon the State’s democratic and electoral
machinery. On Plaintiff’s reading, a mere “five percent of the legal voters in
each of two-thirds of the congressional districts in the state,” Mo. Const. art.
III, § 52(a), can suspend the General Assembly’s congressional redistricting
plan even after more than 1.2 million Missourians voted in primary elections
under the plan. Plaintiff, moreover, asks the Court to set aside the General
Assembly’s plan and order placement of hundreds of thousands of voters into
different districts for the imminent 2026 general election than the districts they
voted in barely two weeks ago during the primary elections.
It is difficult to imagine a judicial action that would sow more confusion
among the State’s electorate or inflict more damage to the public’s confidence
in the integrity of the State’s elections than the relief Plaintiff seeks.
Fortunately—and unsurprisingly—both Missouri and federal law foreclose
Plaintiff’s claim. The Missouri Constitution’s sole provision addressing
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congressional redistricting vests authority to conduct it in “the general
assembly.” Id. art. III, § 45 (emphasis added); see also U.S. Const. art. I, § 4,
cl. 1 (vesting in state legislatures authority to “prescribe[]” the “Times, Places,
and Manner of holding Elections for . . . Representatives,” “but the Congress
may at any time by Law make or alter such Regulations”). The Missouri
Constitution’s
referendum
provisions
say
precisely
nothing
about
congressional redistricting, see Mo. Const. art. III, §§ 49, 52(a)-(b), so they lack
the clear statement required to oust the General Assembly’s redistricting
authority. And even if this dispositive defect in Plaintiff’s legal theory were not
enough, Plaintiff’s requested relief violates state and federal law. The Court
should dismiss the Petition and enter judgment for Defendant.
BACKGROUND
The General Assembly enacted House Bill 1 (HB 1) on September 12,
2025. HB 1 repealed Missouri’s prior congressional districting plan and
established new boundaries for Missouri’s eight congressional districts. HB 1
passed by a margin of 21 to 11 in the Senate and 90 to 65 in the House of
Representatives. See Mo. Senate J. 25–26 (2d Extra. Sess., 103d Gen.
Assembly, Sept. 12, 2025); Mo. House J. 37–38 (2d Extra. Sess., 103d Gen.
Assembly, Sept. 9, 2025). Governor Michael L. Kehoe signed HB 1 into law on
September 28, 2025.
A group called People Not Politicians (“PNP”) launched a referendum
campaign to challenge the HB 1 map. PNP eventually submitted a referendum
petition to the Secretary of State on December 9, 2025, invoking the
referendum provisions in Article III of the Missouri Constitution. Under
Article III, Section 52(a), “[a] referendum may be ordered . . . by petitions
signed by five percent of the legal voters in each of two-thirds of the
congressional districts in the state.” Mo. Const. art. III, § 52(a). Article III’s
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referendum provisions are silent regarding congressional redistricting. See id.
art. III, §§ 49, 52(a)-(b).
PNP’s submission triggered the Secretary’s statutory duty to review the
referendum petition. See Maggard v. State, 733 S.W.3d 411, 416 (Mo. banc
2026). That review encompasses the timeliness, legality, and sufficiency of the
petition, as well as the sufficiency of the signatures offered in support of the
petition. See §§ 116.120–116.140, RSMo. “After” review, “if the secretary of
state finds [the petition] sufficient, the secretary of state shall issue a
certificate setting forth that the petition contains a sufficient number of valid
signatures to comply with the Constitution of Missouri and with this chapter.”
§ 116.150.1, RSMo. But “[i]f the secretary of state finds the petition
insufficient, the secretary of state shall issue a certificate stating the reason
for the insufficiency.” § 116.150.2, RSMo.
The Secretary was required to complete this extensive review “not later
than 5:00 p.m. on the thirteenth Tuesday prior to the general election or two
weeks after the date the election authority certifies the results of a petition
verification pursuant to subsection 2 of section 116.130, whichever is later.”
§ 116.150.3, RSMo. The thirteenth Tuesday prior to this year’s general election
fell on Tuesday, August 4, the date of the State’s primary elections.
While the Secretary and Missouri’s local election officials were reviewing
PNP’s submission, two plaintiffs separately challenged HB 1’s effectiveness,
seeking a declaratory judgment and an injunction preventing use of the HB 1
map until voters approved it through the referendum process. See Maggard,
733 S.W.3d at 413. The Missouri Supreme Court unanimously rejected their
claims, holding that “the December 9 referendum petition filing did not
automatically suspend HB 1 under article III, sections 49, 52(a), or 52(b) of the
Missouri Constitution.” Id. at 421. The Missouri Supreme Court also went out
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of its way to emphasize that its decision should not be read as endorsing
referenda on congressional maps. See id. at 414 n.7 (“[T]his opinion
presupposes without deciding HB 1 is subject to the right of referendum.”).
Following the Supreme Court’s ruling, the Attorney General released an
opinion letter requiring “State and local election officials” to “take all
appropriate steps to ensure the HB 1 map is fully implemented in advance of
the 2026 primary elections.” Mo. Att’y Gen., Op. Letter 03-2026 (May 13, 2026).
Local election officials then implemented the HB 1 map in Missouri’s
Centralized Voter Registration (“MCVR”) system, transferring hundreds of
thousands of voters to the new districts. Stipulated Ex. 26 ¶ 7; Stipulated Ex.
29 at 109. After implementation, state and local officials prepared ballots and
conducted the August 4 primary elections under the HB 1 map.
A total of 1,206,871 Missourians voted in the State’s congressional
primary elections under the HB 1 map. See State Of Missouri Election Results
– Primary Election August 4, 2026, available at https://enr.sos.mo.gov/ (last
visited Aug. 17, 2026). Prior to 5 p.m. on August 4, the last day to vote in the
primary elections, Secretary Hoskins announced that he was issuing a
certificate finding PNP’s petition insufficient. See Stipulated Ex. 5. The
Secretary’s certificate identified as “the reason for the insufficiency,”
§ 116.150.2, RSMo., that the Missouri Constitution does not permit referenda
on congressional maps, id. The Secretary’s certificate relied upon a letter from
the Attorney General explaining that insufficiency. See id.
Plaintiff filed this suit later that evening. Plaintiff alleges that “he is
entitled to the immediate suspension of the use and implementation of HB 1.”
Pet. ¶¶ 42-43; see also id. at 8. He also alleges that the Court should “restrain[]
the Secretary from taking further steps to implement or use the congressional
districts in HB 1 to ensure that . . . the correct congressional districts are
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utilized to conduct the 2026 general congressional election.” Id. ¶ 45; see also
id. at 8. Plaintiff’s Petition does not identify what he believes to be “the correct
congressional districts . . . to conduct the 2026 general congressional election.”
Id. ¶ 45. To the extent Plaintiff asks the Court to revert Missouri to the plan
the General Assembly repealed in HB 1, such an action would move hundreds
of thousands of voters into different districts for the imminent 2026 general
election compared to the districts in which they cast their ballots in the August
primary elections just two weeks ago. See, e.g., Order and Judgment, Findings
27, 30, 40-46, Wise v. State, No. 2516-CV29597 (Jackson Cty. Cir. Ct. Mar. 12,
2026); Stipulated Ex. 26 ¶ 7; Stipulated Ex. 29 at 109.
LEGAL STANDARDS
The General Assembly “has the power to do whatever is necessary to
perform its functions except as expressly restrained by the Constitution.” Luther
v. Hoskins, 730 S.W.3d 567, 571 (Mo. banc 2026) (quotations omitted)
(emphasis added). “Deference due the General Assembly requires that doubt
be resolved against nullifying its action if it is possible to do so by . . . any
reasonable construction of the Constitution.” State v. Clay, 481 S.W.3d 531,
537 (Mo. banc 2016) (quotations omitted).
This case also implicates federal law. The U.S. Constitution provides
that “[t]his Constitution, and the Laws of the United States which shall be
made in Pursuance thereof . . . shall be the supreme Law of the Land; and the
Judges in every State shall be bound thereby, any Thing in the Constitution or
Laws of any State to the Contrary notwithstanding.” U.S. Const. art. VI. The
Missouri Constitution enforces this principle, declaring that “Missouri is a free
and independent state, subject only to the Constitution of the United States.”
Mo. Const. art. I, § 4. Thus, federal law controls over any contrary provision of
the Missouri Constitution or law.
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ARGUMENT
Plaintiff asks this Court to nullify the General Assembly’s duly enacted
congressional map based on nothing more than constitutional silence. Even in
an ordinary case, that gambit would fail because the General Assembly has
power to legislate “except as expressly restrained by the Constitution.” Clay, 481
S.W.3d at 537 (quotations omitted). But this is no ordinary case. The General
Assembly enacted HB 1 under both an express state constitutional command,
Mo. Const. art. III, § 45, and an express federal constitutional grant, see U.S.
Const. art. I, § 4. If there were ever a context demanding a clear statement
before the General Assembly’s authority could be displaced, this is it. But there
is nothing—not a word—in Missouri’s referendum provisions addressing
congressional redistricting. Plaintiff’s claim therefore fails.
If more were somehow needed, Plaintiff’s claim fails on at least three
more independent grounds. First, even if the referendum provisions’ silence
could be read to extend them to congressional redistricting, the U.S.
Constitution invalidates Article III, Section 52(b) as applied to a congressional
map enacted by the General Assembly. Second, federal law forecloses any
alteration to Missouri’s congressional map for the ongoing 2026 election. Third,
equitable principles previously applied by the Missouri Supreme Court and the
U.S. Supreme Court likewise bar any changes to the General Assembly’s duly
enacted map at this late juncture. This Court should dismiss the Petition.
I.
Missouri’s Referendum Provisions
Congressional Redistricting.
Do
Not
Apply
To
The Court should dismiss Plaintiff’s Petition because the referendum
provisions in Article III of the Missouri Constitution do not apply to
congressional redistricting.
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A. Article III Does Not Subject Congressional Redistricting To
The Referendum.
This Court need not look beyond Missouri principles of constitutional
interpretation to reject Plaintiff’s claim. Article III expressly directs that “the
general assembly shall by law divide the state into [congressional] districts.”
Mo. Const. art. III, § 45. As the Missouri Supreme Court has recognized, this
is the only constitutional provision addressing congressional redistricting—
and it recognizes the General Assembly’s authority and mandate over that
task. Luther, 730 S.W.3d at 571.
When the General Assembly conducts congressional redistricting, it acts
not only under this express state constitutional command but also under an
express federal constitutional grant of authority. The Elections Clause
provides that the “Times, Places and Manner of holding Elections for Senators
and Representatives, shall be prescribed in each State by the Legislature
thereof,” subject to laws enacted by Congress. U.S. Const. art. I, § 4. The
General Assembly’s power to conduct congressional redistricting, therefore, is
a uniquely robust legislative authority—emanating from a dual mandate
prescribed by both the state and federal constitutions—layered on top of its
plenary power to do whatever is necessary to perform its functions “except as
expressly restrained by the Constitution.” Luther, 730 S.W.3d at 571
(quotations omitted).
Given the General Assembly’s unique authority over congressional
redistricting, this Court should not lightly infer that the Missouri Constitution
elsewhere divested that authority absent a clear statement. Missouri courts
interpret the Constitution to effectuate its “plain, ordinary, and natural
meaning,” and any provision must be “considered as a whole with the primary
objectives of the provision in issue in mind.” Id. (quotations omitted); see also
Mo. Prosecuting Att’ys v. Barton Cty., 311 S.W.3d 737, 741 (Mo. banc 2010)
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(explaining that “due regard is given to the primary objectives of the provision
at issue as viewed in harmony with all related provisions, considered as a
whole”) (quotations omitted). Applying those principles here, the Missouri
Constitution could not be more explicit that congressional redistricting belongs
to the General Assembly. See Mo. Const. art. III, § 45. And this is no ordinary
authority; it is a significant power stemming from the U.S. Constitution over
the very structure of democratic representation in Missouri. A reasonable
reader, understanding this context, would expect the Missouri Constitution to
speak clearly before concluding that authority had been limited or taken away.
This expectation of clarity is not novel in Missouri law. Missouri courts
apply it across multiple doctrinal areas, each reflecting that where the law
establishes a settled default, courts do not presume it has been silently
displaced. For example, Missouri courts presume that statutes apply only
within the State’s borders unless the General Assembly clearly says otherwise.
Tuttle v. Dobbs Tire & Auto Centers, Inc., 590 S.W.3d 307, 311 (Mo. banc 2019).
In addition, Missouri courts presume the State cannot be sued unless the
General Assembly expressly waives the State’s immunity. Ramirez v. Mo.
Prosecuting Att’ys, 694 S.W.3d 432, 436 (Mo. banc 2024). And Missouri courts
presume that statutes operate prospectively unless the legislature’s intent for
retroactive application “clearly appears from the express language of the act or
by necessary or unavoidable implication.” Lincoln Credit Co. v. Peach, 636
S.W.2d 31, 34 (Mo. banc 1982).
In each context, the principle is the same: A reasonable reader knows the
baseline under Missouri law and expects clarity before concluding it has been
changed. That principle also animates the Missouri Supreme Court’s
substantial deference to the General Assembly’s exercise of its plenary
legislative power recognized by the Missouri Constitution. Missouri law’s
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baseline expectation that the General Assembly can exercise any and all
legislative power is so strong that the Missouri Supreme Court refuses to
nullify legislative acts under the Missouri Constitution if “it is possible to do
so by . . . any reasonable construction of the Constitution” or by resolving any
“doubt . . . against nullifying its action.” Clay, 481 S.W.3d at 537. If anything,
the expectation of clarity applies even more strongly here because
congressional redistricting represents the rare circumstance where the
General Assembly wields a dual mandate under the State and U.S.
Constitutions. See Mo. Const. art. III, § 45; U.S. Const. art. I, § 4. In other
words, because an express restraint is necessary to limit the General
Assembly’s legislative authority recognized by the Missouri Constitution, such
a restraint at a minimum is required to limit the General Assembly’s exercise
of its congressional redistricting authority both recognized by the Missouri
Constitution and granted by the U.S. Constitution. See Luther, 730 S.W.3d at
571.
Against that backdrop, Plaintiff points only to the generic referendum
provision in Article III, Section 49, which provides that “[t]he people reserve
power . . . to approve or reject by referendum any act of the general assembly.”
Mo. Const. art. III, § 49; see Petition ¶ 4. But that provision at most merely
raises, but does not answer, the question whether the referendum power
extends to congressional redistricting, a domain Article III and the U.S.
Constitution separately and specifically assign to the General Assembly. A
generic provision that says nothing about congressional redistricting cannot do
the work of divesting the General Assembly of the dual mandate the Missouri
and U.S. Constitutions assign to it. Because Section 49 does not “expressly
restrain[]” the General Assembly’s authority over congressional redistricting,
it cannot limit, let alone oust, the General Assembly’s exercise of that
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authority. Luther, 730 S.W.3d at 571 (quotations omitted). And any doubt on
that score must be resolved in favor of the General Assembly, not against it.
See Clay, 481 S.W.3d at 537.
B. Context Confirms That Congressional Redistricting Is Not
Subject To The Referendum.
Context only confirms that a congressional redistricting statute duly
enacted by the General Assembly cannot be subjected to the referendum
process. Three features of Missouri’s legal landscape reinforce this conclusion.
First, in the more than eighty years since Missouri ratified its current
Constitution in 1945, no referendum petition directed at a congressional
redistricting plan has ever reached the ballot. The lone attempt before
Maggard occurred in 1952, when a group filed referendum petitions against
the congressional map, but the petitions were held untimely because the
statute had already taken effect. See State ex rel. Moore v. Toberman, 250
S.W.2d 701, 705-06 (Mo. banc 1952). The complete absence of any successful
referendum on a congressional map over eight decades of practice underscores
that Missouri never deliberately chose to extend the referendum power to this
domain. Indeed, given the relative ease of collecting signatures of “five percent
of the legal voters in each of two-thirds of the congressional districts in the
state,” Mo. Const. art. III, § 52(a)—and the charged political stakes involved in
redistricting—one would expect that political opponents of the majority party
in the General Assembly would have forced a referendum on a congressional
redistricting plan long ago if Missouri law provided a viable path to do so. But
no such thing has occurred.
Second, the 1945 Constitution itself repudiated the only Missouri
Supreme Court decision that had ever sanctioned a referendum on legislative
redistricting of any kind. In State ex rel. Gordon v. Becker, 49 S.W.2d 146 (Mo.
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banc 1932), a divided court permitted a referendum challenging state senate
redistricting. The Constitutional Convention responded by inserting Article
III, Section 7, which expressly declares that “[n]o redistricting plan shall be
subject to the referendum.” Mo. Const. art. III, § 7(h) (1945). The Convention
thus eliminated referenda in the only redistricting context in which any
Missouri court had approved such a referendum. See Debates of the 1943–1944
Constitutional Convention of Missouri 7016 (2008). That deliberate rejection
only confirms the Missouri Framers’ distrust of referenda in the redistricting
sphere.
Third, Chapter 116, the statutory “framework for exercising the right of
referendum” the General Assembly enacted in 1980, see No Bans on Choice v.
Ashcroft, 638 S.W.3d 484, 487 (Mo. banc 2022), is incompatible with referenda
on congressional maps. Two features are particularly telling. As an initial
matter, Chapter 116 restricts the ballot summary for any referendum measure
to a mere hundred words and makes no provisions for visual aids such as maps.
See § 116.334, RSMo. Congressional redistricting is a uniquely complex
undertaking involving considerations of population, compactness, geography,
and communities of interest. See generally Healey v. State, 732 S.W.3d 827 (Mo.
banc 2026). The notion that voters could meaningfully evaluate competing
redistricting plans based solely on a hundred-word description defies reason.
Had the General Assembly contemplated that Chapter 116 would govern
referenda on congressional maps, it surely would have written it to furnish
voters with far more information so they could make an informed choice
regarding that complex issue.
Moreover, Chapter 116 sets the presumptive deadline for the Secretary’s
certification decision on the very same day as the August primary elections.
See § 116.150.3, RSMo. No rational legislature would impose a certification
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timeline that extends to—or past—primary election day if it believed that a
referendum could displace the congressional map under which the very
primary was conducted.
These points confirm what the text already establishes: Missouri has
never—by constitutional provision, by statute, or by practice—subjected
congressional redistricting to the referendum. At every turn where the
question might have been addressed, Missouri’s framers and legislators either
remained silent or affirmatively rejected referenda on redistricting.
C. The Referendum Provisions Themselves Can Be Read To
Exempt Congressional Maps From Their Coverage.
If that were not enough, the text of Article III’s referendum provisions
themselves underscore that they exempt congressional redistricting from their
reach. Article III, Section 52(a) carves out from the referendum process “laws
necessary for the immediate preservation of the public peace, health or safety.”
Mo. Const. art. III, § 52(a). Legislation qualifies for this exception when there
is “a crisis or emergency which requires immediate or quick legislative action
for the preservation of the public peace, property, health, safety, or morals.”
State ex rel. Tyler v. Davis, 443 S.W.2d 625, 631 (Mo. banc 1969).
Missouri courts have explained that this standard is satisfied when
federal law imposes a deadline that the State must meet through prompt
legislation. For example, in Osage Outdoor Advertising, Inc. v. State Highway
Commission, 687 S.W.2d 566, 569-70 (Mo. App. 1984), the federal Highway
Beautification Act required Missouri to enact effective billboard-control
legislation before a set date or lose ten percent of its federal highway
appropriation. After the General Assembly passed the required statute, the
court upheld it as emergency legislation, explaining that “[t]his sequence of
events demonstrates the necessity for immediate action by the legislature and
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prompt enactment of the law.” Id. at 569.
The case for the exception is even stronger here. Federal law requires
each State’s Legislature to prescribe the times, places, and manner of holding
congressional elections. See U.S. Const. art. I, § 4. Federal law also imposes
several constitutional and statutory mandates with which Missouri must
comply, including a nationwide federal general election day on the first
Tuesday in November of even-numbered years, 3 U.S.C. § 1; 2 U.S.C. §§ 1, 7,
and a strict 45-day ballot transmission requirement prior to any federal
primary or general election, 52 U.S.C. § 20302(a)(8); see also infra at 29-30.
HB 1 is the legislation through which Missouri satisfies those federal
requirements for congressional elections. Just as the billboard statute in Osage
was necessary to avoid the loss of federal highway funds, HB 1 is necessary to
avoid a far graver consequence: the inability to hold a constitutionally valid
election. “[T]he political franchise of voting” has long been recognized as
“preservative of all rights,” Harper v. Va. State Bd. of Elections, 383 U.S. 663,
667 (1966) (quotations omitted), and legislation that makes a federal election
possible is plainly necessary to preserve the public peace. It cannot be held
hostage by a small minority of voters who prefer a different redistricting plan—
particularly when that minority seeks to impose on the public a different plan
in the weeks between a primary and a general election.
This exception provides yet another textual basis to conclude that
congressional redistricting legislation is not subject to the referendum. And
even if this Court were not persuaded that this exception exempts
congressional redistricting from the referendum, it at minimum creates doubt
about whether the referendum power reaches this domain. Once again, the
Court must resolve any such doubt in favor of the General Assembly’s enacted
map. Clay, 481 S.W.3d at 537.
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II.
Federal Law Independently Confirms That Missouri Has Not
Ousted The General Assembly’s Redistricting Authority.
Although Missouri law alone requires dismissal of the Petition, federal
law provides an independent basis for dismissal. As explained, when the
General Assembly conducts congressional redistricting, it wields authority
expressly granted it by the U.S. Constitution’s Elections Clause. See U.S.
Const. art. I, § 4. Federal law, in turn, imposes its own clear statement
requirement before this federal legislative authority can be displaced.
Missouri’s referendum provisions do not satisfy that requirement for the same
reasons they fail it under Missouri law: They say nothing about congressional
redistricting.
A. Clear Statement Rules Protect and Uphold
Constitution’s Express Delegations of Authority.
The
U.S.
Enforcing constitutional boundaries ranks among courts’ most vital
duties. Given the tendency of institutions to encroach on each other’s powers,
see THE FEDERALIST No. 51 (James Madison) (C. Rossiter ed., 1961), courts
must serve as a “bulwark[]” against those incursions, THE FEDERALIST No. 78
(Alexander Hamilton) (C. Rossiter ed., 1961). Consistent with that role, courts
will not lightly infer a significant restructuring of a constitutional allocation of
power. Where the Constitution assigns authority to a specific actor, that power
cannot be divested absent a clear statement. See West Virginia v. EPA, 597
U.S. 697, 735 (2022) (Gorsuch, J., concurring) (explaining that clear-statement
rules “operate[] to protect foundational constitutional guarantees”).
Courts deploy an array of clear statement rules to safeguard the
prerogatives of each branch of the federal government in its proper sphere. For
example, Article I of the Constitution delegates responsibility “to make the
laws that govern us” to “the people’s elected representatives.” Nat’l Fed’n of
Indep. Bus. v. OSHA, 595 U.S. 109, 124 (2022) (Gorsuch, J., concurring). To
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protect Article I’s grant of authority, courts will not infer that Congress
delegated to executive agencies the power to resolve major policy questions
absent a clear statement. FDA v. Brown & Williamson Tobacco Corp., 529 U.S.
120, 159-60 (2000). This expectation of clarity reflects and reinforces the
constitutional structure. See West Virginia, 597 U.S. at 723 (explaining that
the major questions doctrine rests on “both separation of powers principles and
a practical understanding of legislative intent”). “Because the Constitution
vests Congress with ‘all legislative Powers,’ a reasonable interpreter would
expect it to make the big-time policy calls itself, rather than pawning them off
to another branch.” Biden v. Nebraska, 600 U.S. 477, 515 (2023) (Barrett, J.,
concurring) (citation omitted). Accordingly, the clear statement rule keeps the
legislative power “where . . . it belongs.” Nat’l Fed’n of Indep. Bus., 595 U.S. at
124 (Gorsuch, J., concurring).
Clear statement rules likewise protect the President’s constitutional
prerogatives in Article II. It is axiomatic that “[t]he President is the sole organ
of the nation in its external relations, and its sole representative with foreign
nations.” United States v. Curtiss-Wright Export Corp., 299 U.S. 304, 319
(1936) (quotations omitted). So “unless there is the affirmative intention of the
Congress clearly expressed to give a statute extraterritorial effect,” courts will
presume it does not apply extraterritorially. Morrison v. Nat’l Australia Bank
Ltd., 561 U.S. 247, 255 (2010) (cleaned up). In this context, the clear statement
rule reflects the structural principle that Congress does not ordinarily intend
to intrude on the President’s authority to conduct foreign relations. See RJR
Nabisco, Inc. v. European Community, 579 U.S. 325, 348 (2016).
Underscoring the point, federal courts routinely employ clear statement
rules to protect their Article III authority. Federal courts will not imply a
repeal of their jurisdiction in “the absence of clear congressional language
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mandating” that result. McNary v. Haitian Refugee Ctr., Inc., 498 U.S. 479,
483-84 (1991); see also Goncalves v. Reno, 144 F.3d 110, 122 (1st Cir. 1998)
(applying “the long standing rule disfavoring repeal of jurisdictional provisions
by implication”). For example, the U.S. Supreme Court has long required that
if Congress intends to make exceptions to the Supreme Court’s appellate
jurisdiction it must do so with unmistakable clarity, not “by mere implication.”
Ex parte Yerger, 75 U.S. 85, 106 (1869). This principle ensures that any
retrenchment of federal courts’ core functions occurs, if at all, only by Congress
speaking with the clarity the Constitution’s separation of powers demands.
Clear statement rules also help police the “constitutional balance of
federal and state powers.” Gregory v. Ashcroft, 501 U.S. 452, 460 (1991). The
Constitution’s structure, including the Tenth Amendment’s reservation of
powers, counsels restraint in inferring federal limitations on state authority.
Hence, “if Congress intends to alter the usual constitutional balance between
the States and the Federal Government, it must make its intention to do so
unmistakably clear in the language of the statute.” Will v. Michigan Dep’t of
State Police, 491 U.S. 58, 65 (1989) (cleaned up). This clear statement rule
governs attempts to displace state sovereign immunity, see Seminole Tribe v.
Florida, 517 U.S. 44, 55 (1996) (“unequivocal[] express[ion]” required “to
abrogate the immunity”) (quotations omitted), to preempt state legislation,
Rice v. Santa Fe Elevator Corp., 331 U.S. 218, 230 (1947) (courts will assume
state police powers not superseded “unless that was the clear and manifest
purpose of Congress”), to impose conditions on states accepting federal funds,
see Pennhurst State Sch. & Hosp. v. Halderman, 451 U.S. 1, 17 (1981)
(“unambiguous[]” language required to “impose a condition on the grant of
federal moneys”), and to criminalize conduct traditionally regulated by the
states, Bond v. United States, 572 U.S. 844, 857 (2014) (absent “clear
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indication,” courts will not read statutes to “intrude[] upon traditional state
criminal jurisdiction”) (quotations omitted).
In short, across multiple doctrinal settings, clear statement rules serve
as a structural safeguard ensuring that only a deliberately expressed choice—
not ambiguity or implication—can recalibrate the Constitution’s usual balance
of shared authorities among competing actors.
B. The Elections Clause Requires A Clear Statement To Displace
The State Legislature’s Redistricting Authority.
The Elections Clause, no less than other enumerated delegations,
requires a clear statement before courts may determine that a state has
reallocated power over redistricting from the state legislature. This clear
statement rule flows from the Elections Clause itself, which expressly provides
that “[t]he Times, Places and Manner of holding Elections for Senators and
Representatives, shall be prescribed in each State by the Legislature thereof;
but the Congress may at any time by Law make or alter such Regulations . . . .”
U.S. Const. art. I, § 4 (emphasis added).
This delegation reflects a reasoned constitutional settlement. The
Framers recognized “electoral districting problems and considered what to do
about them,” and they “settled on a characteristic approach, assigning the
issue to the state legislatures, expressly checked and balanced by the Federal
Congress.” Rucho v. Common Cause, 588 U.S. 684, 699 (2019). Courts “must
respect” the Constitution’s “deliberate choice” to “expressly vest[] power” to
conduct congressional redistricting “in ‘the Legislature’ of each State.” Moore
v. Harper, 600 U.S. 1, 34 (2023).
As with other express delegations in the U.S. Constitution, courts
require a clear statement before concluding that a state has displaced its
legislature’s authority over congressional redistricting. It is well established
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that Congress must employ “positive and clear statutes” in order to override a
state legislature’s prerogative to regulate federal elections. United States v.
Gradwell, 243 U.S. 476, 485 (1917); see also United States v. Oregon, 828 F.
Supp. 3d 1092, 1095-96 (D. Or. 2026) (same, citing Gradwell, 243 U.S. at 485);
United States v. Caldwell, No. CV 26-2025 (ZNQ) (JTQ), 2026 WL 2186515, at
*3 (D.N.J. July 29, 2026) (same, citing Gradwell, 243 U.S. at 485). Because
Congress—the sole actor the Elections Clause empowers to supersede state
legislative regulations—may do so only through unmistakable, affirmative
enactments, any contention that some state actor or process has displaced the
state legislature’s redistricting role must at a minimum rest on equally explicit
and unequivocal language.
The U.S. Supreme Court’s Elections Clause cases confirm the point. In
State of Ohio ex rel. Davis v. Hildebrant, the U.S. Supreme Court considered
whether a constitutional referendum could displace the Ohio General
Assembly’s authority to redistrict. 241 U.S. 565, 566-67 (1916). The U.S.
Supreme Court concluded that it could only because state law “conclusive[ly]”
“ma[d]e[] it clear that . . . the referendum constituted a part of the state
Constitution and laws” applicable to congressional redistricting. Id. at 568.1
More recently, in Arizona State Legislature v. Arizona Independent
Redistricting Commission, the U.S. Supreme Court weighed whether Arizona
could create an independent commission to draw congressional districts. 576
U.S. 787, 792-93 (2015). The U.S. Supreme Court sustained that arrangement
1 Hildebrant is also distinguishable because it pre-dated the U.S. Supreme Court’s one-person, one-
vote jurisprudence and other subsequent legal developments that require states to conduct
congressional elections in equipopulous single-member districts. See, e.g., Kirkpatrick v. Preisler, 394
U.S. 526 (1969). Thus, at the time of Hildebrant, extending a referendum process to a legislature’s
duly enacted congressional districting plan did not place the state in peril of violating the one-person,
one-vote mandate or other federal requirements that foreclose Plaintiff’s claim and requested relief
here. See, e.g., infra Parts III-IV. Moreover, Hildebrant arose in a non-election year, not between a
primary and general election in the same year. See, e.g., infra Parts IV-V.
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because
Arizona’s
Constitution
expressly
“remove[d]
congressional
redistricting authority from the State Legislature.” Id. at 796-97. In both cases,
no doubt existed that the state had deliberately overridden the legislature’s
authority.
C. Missouri’s Referendum Provisions Do Not Provide A Clear
Statement Displacing The General Assembly’s Authority.
The Missouri Constitution does not supply any statement—let alone a
clear one—reallocating authority over congressional redistricting away from
the General Assembly to a referendum process. “Article III, section 45 is the
only provision of the Missouri Constitution directly addressing congressional
redistricting,” Luther, 730 S.W.3d at 571, and it mandates that “the general
assembly shall by law divide the state into [congressional] districts,” Mo. Const.
art. III, § 45 (emphasis added); see supra at 8-9.
In the face of this silence, Plaintiff points only to the generic referendum
provision in Article III, Section 49, which provides that “[t]he people reserve
power . . . to approve or reject by referendum any act of the general assembly.”
Mo. Const. art. III, § 49; see Petition ¶ 4. This is a textbook example of a broad,
undifferentiated clause that does not provide a clear statement overriding the
U.S. Constitution’s express grant of authority over congressional redistricting
to the General Assembly. See Spector v. Norwegian Cruise Line Ltd., 545 U.S.
119, 139 (2005) (plurality opinion) (“[C]lear statement rules ensure [the state]
does not, by broad or general language, legislate on a sensitive topic
inadvertently or without due deliberation.”). Section 49 gives no indication that
Missouri “specifically considered” whether to displace the General Assembly’s
federally assigned authority over redistricting and “intentionally legislated on
the matter.” Sossamon v. Texas, 563 U.S. 277, 290 (2011). Accordingly, it does
not provide a “conclusive” statement divesting the General Assembly of its
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Elections Clause authority over congressional redistricting, much less vesting
that authority in the referendum process. Hildebrant, 241 U.S. at 568. Lacking
any clear statement in Missouri law to support his claim, Plaintiff’s Petition
must fail.
III.
The U.S. Constitution Invalidates Article III, Section 52(B) As
Applied To A Congressional Map Enacted By The Legislature.
Plaintiff’s claim fails for another reason. Even if Missouri’s referendum
provisions could somehow be read to encompass congressional redistricting,
the U.S. Constitution would not permit it. See U.S. Const. art. VI; Mo. Const.
art. I, § 4. Both the Elections Clause and the Guarantee Clause forbid the
application of Article III, Section 52(b) to a congressional map enacted by the
General Assembly.
As discussed, the Elections Clause vests redistricting authority squarely
in the state legislature. See U.S. Const. art. I, § 4; see supra at 22. Indeed, the
U.S. Supreme Court recently cautioned that state law may not be wielded to
“arrogate” the “power vested in state legislatures to regulate federal elections.”
Moore, 600 U.S. at 29.
That is precisely what would happen if Article III, Section 52(b) applies
to congressional maps. Section 52(b) provides that legislation subject to a
referendum is suspended once a sufficient petition is filed. Mo. Const. art. III,
§ 52(b); see also Maggard, 733 S.W.3d at 418. A referendum petition is
sufficient if signed by merely “five percent of the legal voters in each of twothirds of the congressional districts in the state.” Mo. Const. art. III, § 52(a).
On Plaintiff’s theory, a small fraction of voters can freeze a congressional map
duly enacted by the General Assembly before any majority of Missourians has
voted for or against it—and even after that map has been used to conduct
primary elections.
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That theory inverts the constitutional design. The Elections Clause
guarantees that the People’s elected representatives control the time, place,
and manner of federal elections.2 But according to Plaintiff, a small, unelected
minority would wield effective veto power over the General Assembly’s
redistricting decisions. This case illustrates the point. HB 1 passed
overwhelmingly in both chambers of the General Assembly and was signed by
the Governor. See Mo. Senate J. 25–26 (2d Extra. Sess., 103d Gen. Assembly,
Sept. 12, 2025); Mo. House J. 37–38 (2d Extra. Sess., 103d Gen. Assembly,
Sept. 9, 2025). Yet Plaintiff claims that a small minority of voters can suspend
the map months before the election without any statewide vote. The Elections
Clause forbids any arrangement that would so thoroughly “annihilate” the
General Assembly’s redistricting authority. Hildebrant, 241 U.S. at 569.
The Guarantee Clause compels the same conclusion. That clause
provides that “[t]he United States shall guarantee to every State in this Union
a Republican Form of Government.” U.S. Const. art. IV, § 4. It also “necessarily
implies a duty on the part of the States themselves to provide” a republican
form of government. Minor v. Happersett, 88 U.S. 162, 175 (1874). A republican
government is one in which “the scheme of representation takes place”—that
is, the people govern through elected representatives who enact laws on their
behalf. THE FEDERALIST No. 10 (Madison) (C. Rossiter ed., 1961). “[T]he
distinguishing feature of that form is the right of the people to choose their own
officers for governmental administration, and pass their own laws in virtue of
2 “Both the Constitution and our cases make clear that “the Legislature” in the Elections Clause is the
representative body which makes the laws of the people.” Arizona State Legislature v. Arizona Indep.
Redistricting Comm'n, 576 U.S. 787, 827 (2015) (Roberts, CJ, dissenting). In Arizona State Legislature,
the four members of the dissent strongly opposed the position that the “people” can be the “legislature”
under the Elections Clause. That dissent, penned by Chief Justice Roberts and joined by Justices Alito,
Thomas and Scalia, calls into question the entire validity of a referendum on a congressional district
map and in light of the changed nature of the United States Supreme Court, seems likely to now
consist of a majority view of the members of the current court.
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the legislative power reposed in representative bodies, whose legitimate acts
may be said to be those of the people themselves.” Duncan v. McCall, 139 U.S.
449, 461 (1891); accord Madden v. Missouri Pac. Ry. Co., 192 S.W. 455, 458
(Mo. banc 1917) (Woodson, J., concurring in the judgment).
Plaintiff’s proposed regime is the antithesis of a republican form of
government. On his theory, a small minority of voters can nullify a
congressional map enacted by the People’s elected representatives without any
majority vote. See THE FEDERALIST No. 22 (Hamilton) (C. Rossiter ed., 1961);
THE FEDERALIST No. 58 (Madison) (C. Rossiter ed., 1961) (“it would no longer
be the majority that would rule: the power would be transferred to the
minority”). And Plaintiff’s requested remedy makes the affront even starker:
he seeks the “immediate suspension” of HB 1, Pet. ¶¶ 42-43, which would leave
Missouri with no congressional map whatsoever for the imminent general
election (except, presumably, one ordered by the judiciary). Permitting a sliver
of the electorate to void the “legitimate acts . . . of the people themselves”
cannot be squared with Missouri’s constitutional duty to maintain a republican
form of government. Duncan, 139 U.S. at 461.
IV.
Federal Law Forecloses Any Alteration to Missouri’s
Congressional Map At This Late Stage Of The Electoral Process.
Even if this Court were to conclude that the Missouri Constitution
authorizes referenda on congressional maps and that the U.S. Constitution
does not invalidate Section 52(b) as applied, federal law would still prohibit
Plaintiff’s
requested
relief:
“immediate
suspension
of
the
use
and
implementation of HB 1.” Pet. ¶¶ 42-43; see also id. at 8. More than 1.2 million
Missourians have already voted under the HB 1 map in the primary elections.
See State Of Missouri Election Results – Primary Election August 4, 2026,
available at https://enr.sos.mo.gov/ (last visited Aug. 17, 2026). Plaintiff asks
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the Court to nullify those votes and adopt some other congressional map for
the imminent general election. Doing so would violate federal law several times
over.
First, UOCAVA protects the voting rights of military servicemembers
and citizens living abroad by requiring state election officials to transmit
absentee ballots no fewer than 45 days before any federal election. See 52
U.S.C. § 20302(a)(8); see also § 115.914, RSMo. That requirement applies
independently to each federal election, including a primary. Accordingly, if this
Court were to suspend the use of HB 1, UOCAVA would require ballot
transmission to military and overseas voters 45 days before any primary under
the new map. Missouri law would then require a three-day waiting period after
the primary before the results could be certified. See §§ 115.920.1, 115.508,
RSMo. And UOCAVA would again require ballot transmission 45 days before
the subsequent general election on November 3, 2026. 3 U.S.C. § 1; 2 U.S.C.
§§ 1, 7. The arithmetic is straightforward: The State needs 93 days minimum
before the general election on November 3, 2026, to comply with the federal
election day statute and UOCAVA.
That deadline has already passed. See Foster v. Love, 522 U.S. 67, 74
(1997) (holding that a State may not conduct federal elections in conflict with
congressionally mandated timing under 2 U.S.C. § 7). An injunction against
HB 1 would therefore require state officials to violate federal law. And
UOCAVA is enforceable by the U.S. Attorney General in federal court, 52
U.S.C. § 20307(a), meaning that Plaintiff’s requested relief would expose
Missouri officials to an adverse federal injunction. The Secretary correctly
avoided that result by declining to certify the referendum petition. See
Stipulated Ex. 5 at 9-10.
Second, holding a general election under a different congressional map
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than the one used in the August 4 primary would violate Article I, Section 2 of
the U.S. Constitution. That provision guarantees that “[t]he House of
Representatives shall be composed of Members chosen every second Year by
the People of the several States.” U.S. Const. art. I, § 2. The U.S. Supreme
Court has long recognized that “[w]here the state law has made the primary
an integral part of the procedure of choice,” then “the right of the elector to
have his ballot counted at the primary[] is likewise included in the right
protected by Article I, § 2.” United States v. Classic, 313 U.S. 299, 318 (1941).
Missouri law makes the primary integral: “all candidates for elective
office shall be nominated at a primary election,” § 115.339, RSMo., and “[t]he
person receiving the greatest number of votes at a primary election as a party
candidate for an office shall be the only candidate of that party for the office at
the general election,” § 115.343, RSMo. A candidate may be replaced only if he
or she dies, is disqualified, or voluntarily withdraws. See § 115.363.3(1)-(3), .4
RSMo. The Missouri Supreme Court has thus confirmed that “primary
elections have constitutional stature” and serve as an “integral part of [the
State’s] election machinery.” State ex rel. McClellan v. Kirkpatrick, 504 S.W.2d
83, 86 (Mo. banc 1974) (emphasis added).
Plaintiff’s requested relief plainly violates the right of Missouri voters to
have their ballot counted. More than 1.2 million Missourians voted in the
August 4 congressional primaries under the HB 1 map and selected nominees
in each of Missouri’s eight districts. Plaintiff asks this Court to ignore those
votes, see Pet. ¶¶ 42-43; see also id. at 8, stripping the nominees of the mandate
their voters conferred. Article I, Section 2 forbids this result.
Third, an order requiring a general election under a different
congressional map than the one used in the primary would violate the Equal
Protection Clause. U.S. Const. amend. XIV, § 1. The U.S. Supreme Court has
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held that primary-election procedures constitute “‘state action’ within the
meaning of the Fourteenth Amendment” and “must be exercised in a manner
consistent with the Equal Protection Clause.” Bullock v. Carter, 405 U.S. 134,
140-41 (1972). The Supreme Court has also made clear that “[o]nce the
geographical unit for which a representative is to be chosen is designated, all
who participate in the election are to have an equal vote . . . wherever their
home may be in that geographical unit.” Gray v. Sanders, 372 U.S. 368, 379
(1963).
Plaintiff’s proposed remedy would violate this standard. If the
congressional map changes between the primary and general elections, it
would force hundreds of thousands of Missourians to vote in a district different
from the one in which they cast their primary ballots. Those voters would
possess materially less voting power than voters whose district remained the
same because the former group would have to select from candidates they
never had the opportunity to evaluate, support, or oppose in the primary. They
would thus be denied the right to choose their own representative through the
integrated primary and general elections. Meanwhile, voters who happened to
remain in the same district would retain the full benefit of their primary vote.
An order changing the congressional map would thus create two classes of
voters—those who had the opportunity to select their general election
candidate and those who did not—in direct violation of the Equal Protection
Clause.
In short, regardless of how this Court reads the Missouri Constitution,
it cannot order the State to use a different congressional map than the one
under which Missouri conducted the 2026 primary elections. Federal law
precludes that result.
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V.
The Court Should Not Order Any Changes To The General
Assembly’s Duly Enacted Map For The Ongoing 2026 Election.
Finally, even setting aside the various insurmountable barriers to
Plaintiff’s claim, fundamental equitable principles applied by the Missouri
Supreme Court and the U.S. Supreme Court in prior cases also foreclose any
changes to the General Assembly’s duly enacted map for the ongoing 2026
election. Missouri has already completed its August 4 primary elections, in
which over 1.2 million Missourians selected nominees who are now the only
candidates of their respective parties for the general election, see § 115.343,
RSMo., which will be completed in only eleven weeks from now. Any judicially
ordered changes to the map at this late juncture would “result in voter
confusion and consequent incentive to remain away from the polls” and erode
the “[c]onfidence in the integrity of our electoral processes . . . essential to the
functioning of our participatory democracy.” Purcell v. Gonzalez, 549 U.S. 1, 45 (2006); accord Hadley v. Junior Coll. Dist. of Metro. Kansas City, 460 S.W.2d
1, 2 (Mo. banc 1970).
Months ago, the U.S. Supreme Court stayed a three-judge federal district
court’s order enjoining use of Texas’s 2025 congressional redistricting plan and
requiring the State to revert to its 2022 plan. Abbott v. League of United Latin
American Citizens, 607 U.S. ----, 146 S. Ct. 418, 419 (2025). The district court
issued its injunction shortly after the opening of candidate filing,
approximately four months before the primary, and eleven months before the
November 2026 general election. See League of United Latin Am. Citizens v.
Abbott, 809 F. Supp. 3d 502 (W.D. Tex. 2025). The U.S. Supreme Court issued
the stay because the district court had “improperly inserted itself into an active
primary campaign, causing much confusion” with its late-breaking injunction.
Abbott, 146 S. Ct. at 419; see Robinson v. Ardoin, 37 F.4th 208, 228-29 (5th Cir.
2022) (per curiam), stay issued sub nom., Ardoin v. Robinson, 142 S. Ct. 2892,
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2892-93 (June 28, 2022) (staying injunction of congressional redistricting plan
issued five months before primary elections); Callais v. Landry, 732
F. Supp. 3d 574, 613-14 (W.D. La. Apr. 30, 2024), stay issued sub nom.,
Robinson v. Callais, 144 S. Ct. 1171 (May 15, 2024) (staying injunction of
congressional redistricting plan issued more than six months before the next
election).
It is a “basic tenet of election law” that “[w]hen an election is close at
hand, the rules of the road should be clear and settled.” Democratic Nat’l
Comm. v. Wis. State Legislature, 141 S. Ct. 28, 31 (2020) (mem.) (Kavanaugh,
J., concurring). “[L]ate-breaking, court-ordered rule changes can ‘result in
voter confusion and consequent incentive to remain away from the polls,’ and
thus undermine the ‘[c]onfidence in the integrity of our electoral processes . . .
essential to the functioning of our participatory democracy.’” Bost v. Ill. State
Bd. of Elections, 607 U.S. ----, 146 S. Ct. 513, 521 (2026) (quoting Purcell, 549
U.S. at 4-5); see also Abbott, 146 S. Ct. at 419. After all, “running a statewide
election is a complicated endeavor,” involving “a host of difficult decisions
about how best to structure and conduct the election.” Democratic Nat’l Comm.,
141 S. Ct. at 31 (Kavanaugh, J., concurring). And those decisions must then be
communicated to the “state and local officials” tasked with implementing them,
who in turn “must communicate to voters how, when, and where they may cast
their ballots through in-person voting on election day, absentee voting, or early
voting.” Id. When a “court alters election laws near an election,” id.,
candidates, voters, and even officials are left scrambling to understand the
court-imposed alteration, “inviting confusion and chaos and eroding public
confidence in electoral outcomes,” id. at 30 (Gorsuch, J., concurring).
These considerations counsel judicial restraint and deference to the
democratic process on the eve of an election. The General Assembly is
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responsible for redrawing the State’s congressional districts. See Mo. Const.,
art. III, § 45; U.S. Const. art. I, § 4, cl. 1; see also Ariz. State Legis. v. Ariz. Ind.
Redistricting Comm’n, 576 U.S. 787, 808 (2015). This allocation makes
practical sense. Legislatures “enjoy far greater resources for research and
factfinding” than courts, and “make policy and bring to bear the collective
wisdom of the whole people when they do, while courts dispense the judgment
of only a single person or a handful.” Democratic Nat’l Comm., 141 S. Ct. at 29
(Gorsuch, J., concurring). “It is one thing for state legislatures to alter their
own election rules in the late innings and to bear the responsibility for any
unintended consequences. It is quite another thing for a . . . court to swoop in
and alter carefully considered and democratically enacted state election rules
when an election is imminent.” Id. at 31 (Kavanaugh, J., concurring).
Missouri’s own precedent reinforces these principles. In Hadley v. Junior
College District of Metropolitan Kansas City, the Missouri Supreme Court
confronted a remand after the U.S. Supreme Court found that junior college
trustee districts violated the one-person, one-vote principle. See 460 S.W.2d at
1. By the time the Missouri Supreme Court addressed the case, the State’s
election machinery was already in motion. Five candidates had filed for office,
officials had begun printing absentee ballots and adjusting voting machines,
and the State had already incurred substantial expense. Id. at 2-3. Moreover,
the candidate-filing deadline fell just two days away and the election itself
loomed one month out. Id. In light of these considerations, the Missouri
Supreme Court held that “it would be wholly inequitable and impracticable to
attempt at this late date to apply the principles enunciated” by the U.S.
Supreme Court, and ordered the election to proceed under the existing
apportionment. Id. In other words, even a proven violation of the U.S.
Constitution could not justify disrupting an ongoing election. As the Missouri
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Supreme Court explained, “a court is entitled to and should consider the
proximity of a forthcoming election and the mechanics and complexities of
state election laws, and should act and rely upon general equitable principles.”
Id. at 2 (emphasis added) (quoting Reynolds v. Sims, 377 U.S. 533, 585 (1964)).
This case presents the exact scenario Hadley and Purcell were designed
to prevent. If courts cannot change a congressional map four months before a
primary, see Abbott, 146 S. Ct. at 419, they certainly cannot do so after the
primary has already occurred and mere weeks before the general election.
Candidate filing closed months ago. Over 1.2 million Missourians voted in the
August 4 primary. Nominees have been selected. Campaigns for the general
election are underway. Plaintiff does not even attempt to explain how State
officials could reverse course and implement some entirely new map, how
nominees selected by voters in one set of districts would campaign in different
ones, or how voters would make sense of a last-minute overhaul of the districts
they just voted in. The disruption Plaintiff seeks would dwarf anything
contemplated in Abbott, Ardoin, or Callais—and the U.S. Supreme Court
stayed all of those injunctions as impermissible.
In fact, changing the map at this stage is not merely inequitable, it is
impossible. Missouri election officials are not aware of any precedent, in
Missouri or any other State, in which a court has changed a congressional map
between a State’s primary and general elections. Stipulated Ex. 26 ¶¶ 5, 16.
And for good reason. As one election official explained, implementing a new
congressional map requires local election officials to transfer hundreds of
thousands of individual voters in the MCVR system. Id. ¶ 7; see also Stipulated
Ex. 29 at 109. That is a meticulous process involving careful analysis of printed
maps and multiple rounds of proofreading; it ordinarily takes more than two
weeks, and at least 7-10 days even under emergency conditions. Stipulated Ex.
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26 ¶ 7. But even that timeline is academic here, because the MCVR system
locks shortly before absentee ballots are distributed and remains locked until
an election is certified two weeks after election day. Id. ¶ 8. This year, the
system will remain locked until at least mid-November because of a Jackson
County special election in September 2026. Id. ¶¶ 9-10. The Court should not
order an unprecedented remedy that is impossible to implement. See Hadley,
460 S.W.2d at 3 (refusing to alter districts where doing so would be “wholly
inequitable and impracticable”).
Plaintiff’s own representations to Missouri courts confirm that the
window for relief has long since closed. For months, PNP and von Glahn urged
courts to resolve the status of HB 1 on an expedited basis, insisting that their
challenges were “time-sensitive” given the approaching 2026 elections and the
need to prevent “chaos in August.” Stipulated Ex. 21 at 1-2. Other challengers
to HB 1 pressed for judicial resolution before candidate filing even opened,
conceding that equity would “favor the status quo in a legal dispute during the
lead-up to an election.” See, e.g., Stipulated Ex. 25 at 16 (quotation omitted).
Having told Missouri courts for months that time was running out, Plaintiff
cannot now demand the very relief he previously admitted would come too late.
This Court should follow the settled approach of both the United States
Supreme Court and the Missouri Supreme Court and decline to order any
changes to the General Assembly’s duly enacted map after the primary has
already occurred. See Abbott, 146 S. Ct. at 419; Ardoin, 142 S. Ct. at 2892-93;
see also Hadley, 460 S.W.2d at 2. Such an injunction would “lead to disruption
and to unanticipated and unfair consequences for candidates, political parties,
and voters, among others.” Merrill v. Milligan, 142 S. Ct. 879, 881 (2022)
(Kavanaugh, J., concurring). To “protec[t] the State’s interest in running an
orderly, efficient election and in giving citizens (including the losing candidates
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and their supporters) confidence in the fairness of the election,” Democratic
Nat’l Comm., 141 S. Ct. at 31 (Kavanaugh, J., concurring), this Court should
decline to order any changes to HB 1 for the 2026 election.
CONCLUSION
The Court should dismiss the Petition.
Respectfully submitted,
ELLINGER BELL LLC
By:
/s/ Marc H. Ellinger
Marc H. Ellinger, #40828
Stephanie S. Bell, #61855
Cole D. Bradbury, #62760
308 East High Street, Suite 300
Jefferson City, MO 65101
Telephone: (573) 750-4100
Facsimile: (314) 334-0450
E-mail: mellinger@ellingerlaw.com
Email: sbell@ellingerlaw.com
E-mail: cbradbury@ellingerlaw.com
JONES DAY
By:
/s/ John M. Gore
John M. Gore (pro hac vice)
51 Louisiana Ave., NW
Washington, DC 20001
Telephone: (202) 879-3930
Facsimile: (202) 626-1700
E-mail: jmgore@jonesday.com
Attorneys for Intervenors
CERTIFICATE OF SERVICE
I hereby certify that a true and accurate copy of the foregoing was served
via the Court’s electronic filing system on August 18, 2026 on all parties of
record.
/s/ Marc H. Ellinger
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IN THE CIRCUIT COURT OF COLE COUNTY, MISSOURI
RICHARD VON GLAHN,
Plaintiff,
v.
DENNY HOSKINS, in his official
capacity,
Defendant.
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Case No. 26AC-CC00440
PLAINTIFF’S TRIAL BRIEF
This case is about whether the Secretary of State correctly decided not to
certify the referendum petition on House Bill 1. He did not.
The Secretary claims a referendum is not available because House Bill 1
redraws Missouri’s congressional districts. But House Bill 1 is an act of the
General Assembly, and the Missouri Constitution reserves to the people the
power to approve or reject by referendum “any act of the general assembly”—with
two narrow exceptions, neither of which applies here.
Over a century ago, the United States Supreme Court held that redistricting
bills may be subject to a state referendum without violating the Elections Clause.
That’s still the law. The Secretary’s last-minute decision to reject this
referendum—after months of deliberate delay—cannot be salvaged by meritless
legal analysis. The Secretary complains of a crisis of his own making. The Court
should ignore these complaints and reverse the Secretary’s decision deeming the
Referendum Petition insufficient.
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I.
The Right of Referendum is Inviolate and Reserved to the People
Despite the Secretary’s apparent surprise that a sufficient referendum
petition suspends a law, this is how referenda work. The referendum is a “means
through which the public may have some say with regard to the laws which shall
be enacted.” 42 Am. Jur. 2d Initiative and Referendum § 1. One of the purposes
of a referendum “is to suspend or annul laws which are not yet effective in order
to provide the people a means of expressing their desire regarding a legislative
proposition; a referendum amounts to a veto power over enactments of
representative bodies.” Id. The Missouri Supreme Court and courts across the
country have recognized that’s how referenda function. See Maggard v. State,
733 S.W.3d 411, 420 (Mo. banc 2026) (“If, however, the December 9 referendum
petition filing is ultimately determined to be sufficient . . . HB 1 did not take effect
on December 11, HB 1 was “referred to the people” as of December 9, and HB1
“shall take effect when approved by a majority of the votes cast thereon, and not
otherwise.”); see e.g. State v. Mata, 934 N.W.2d 475, 485 (2019) (“[W]e
concluded that upon filing of a referendum petition appears to have a sufficient
number of signatures, operation of the legislative act is suspended so long as the
verification and certification process ultimately determines that the petition had
the required number of valid signatures.”); Bernstein Bros., Inc., v. Dep’t. of
Revenue, 661 P.2d 537 (1983) (“We concluded that the [referendum] power itself
was created to benefit the majority of the people by suspending operation of a
statute until the people have an opportunity to approve or reject legislation.”);
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Wilde v. City of Dunsmuir, 470 P.3d 590 (Cal. 2020) (“A referendum suspends
operation of the law until it is approved by a majority of voters.”).
Missouri voters first reserved the legislative power to themselves adopted a
constitutional amendment establishing the right of referendum in 1908. No Bans
on Choice v. Ashcroft, 638 S.W.3d 484, 486 (Mo. banc 2022) (citing Marsh v.
Bartlett, 121 S.W.2d 737, 742 (Mo. banc 1938)). This provision “served the one
purpose, to recall all legislative power theretofore granted to the end that the
whole power to be granted should be subject to the initiative and referendum.”
Marsh, 121 S.W.2d at 742. When the people vested legislative authority in the
General Assembly, they “reserve[d] to themselves power to propose laws and
amendments to the Constitution and enact or reject the same at the polls,
independently of the legislative assembly.” Id.
To make this power meaningful, courts have made clear that the provisions
governing referendum “should be construed liberally to the end that [the
people’s] right to determine all proper questions by free and open elections shall
be secure.” State ex rel. Voss v. Davis, 418 S.W.2d 163, 167 (Mo. 1967); see also
Rekart v. Kirkpatrick, 639 S.W.2d 606 (Mo. banc 1982). In other words,
“[p]rovisions reserving to the people the powers of initiative and referendum are
given a liberal construction to effectuate the policy thereby adopted.” Voss, 418
S.W.2d at 167.
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II.
The Missouri Constitution Authorizes Referendum on Acts of
the General Assembly, Including Congressional Maps
The Secretary’s Certificate rests on a fundamental misreading of the
Missouri Constitution. His arguments—and the Attorney General’s supplemental
“opinion”—fail to account for the Constitution’s plain language and the settled
law interpreting it.
The Secretary’s Certificate asserts the Referendum is “insufficient under
the Missouri Constitution because the Missouri Constitution does not authorize a
referendum on congressional redistricting plans passed by the General
Assembly.” Stip. Ex. 5. The Attorney General’s attached “opinion” adds a
requirement: supposedly, the Constitution needs to contain a “clear statement”
specifically authorizing referenda on redistricting bills. Id.
The Secretary’s own words doom his analysis. It is true that the
“congressional redistricting plans [were] passed by the General Assembly.” Id.
That means the people have reserved the right to conduct a referendum. The
plain language of Article III, Sections 49 and 52(a) provide the clearest statement
possible that a referendum on House Bill 1 is available and appropriate.
A.
The Plain Language of the Missouri Constitution Authorizes a
Referendum on Redistricting Legislation
Courts interpret constitutional provisions to give effect to their “plain,
ordinary, and natural meaning.” Wright-Jones v. Nasheed, 368 S.W.3d 157, 159
(Mo. banc 2012). The Supreme Court of Missouri “has repeatedly held, when the
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language of a constitutional provision is clear and unambiguous, [the] Court has
no other duty than to apply the language of the provision as written.” Planned
Parenthood of the St. Louis Region v. Dep’t of Social Services, 602 S.W.3d 201,
214 (Mo. banc 2020). And when the language is clear and unambiguous, the
Court must apply the language as written and “may not resort to canons of
construction to arrive at a different result.” State ex rel. Hillman v. Beger, 566
S.W.3d 600, 605 (Mo. banc 2019).
Here, the words are clear and lead to only one conclusion. Article III,
Section 49 reserves to the people the “power to approve or reject by referendum
any act of the general assembly, except as hereinafter provided.” Mo.
Const. art. III, § 49 (emphasis added). This language is unambiguous: if there is
an act of the general assembly—any act—the people can (with a sufficient number
of signatures) order a referendum.
There can be no doubt about what those words mean. “Any” means “one,
no matter which, of more than two,” or—more simply—“without limit.” Webster’s
New World College Dictionary at 64 (5th ed. 2014). The referendum power thus
covers acts of the General Assembly without limit, except where the Constitution
itself explicitly provides otherwise. The State’s position overlooks those words
and attempts to arrive at a different result. The State asks the Court to insert the
words “except an act of the general assembly that redraws congressional district
lines” into the Constitution. The Court may not do so.
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Congressional redistricting is accomplished by an act of the General
Assembly. Mo. Const. art. III, § 45 (“[T]he general assembly shall by law divide
the state into districts corresponding with the number of [congressional]
representatives to which it is entitled[.]”). House Bill 1—the 2025 congressional
redistricting map—was passed by an “act of the general assembly,” as the bill
itself states. See Pet. Ex. 1; Stip. Ex. 1. It is therefore subject to the referendum
unless it falls within one of the exceptions “hereinafter provided.” Mo. Const. art.
III, § 49.
Article III, Section 52(a) provides only two exceptions to the referendum
power: (1) “[L]aws necessary for the immediate preservation of the public peace,
health or safety”; and (2) “[L]aws making appropriations for the current expenses
of the state government, for the maintenance of state institutions and for the
support of public schools.” Mo. Const. art. III, § 52(a).
House Bill 1 falls within neither exception. It is not a law “necessary for the
immediate preservation of the public peace, health or safety”—indeed, the
Missouri Supreme Court has already examined this measure and determined that
“HB 1 has no emergency clause.” Maggard v. State, 733 S.W.3d 411, 421 n. 8
(Mo. banc 2026); cf. ACLU v. Ashcroft; 577 S.W.3d 881, 884 (Mo. App. 2019)
(“The Secretary of State concluded that because HB 126 contained an emergency
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clause, the act was constitutionally ineligible in its totality for the referendum
process.”). Nor does House Bill 1 make any appropriations. Id.1
Undeterred, the Attorney General attempts to fit congressional
redistricting into the appropriations exception. Stip. Ex. 5. Her theory is that
“suffrage is a fundamental state institution, and congressional redistricting is
necessary to maintain the suffrage right as populations shift over time.” Id. This
argument ignores both a key qualifier and basic grammar. Mo. Const. art. III,
§ 52(a). The exception relates only to appropriations bills, which HB 1 is not.
Every item in the Attorney General’s list—“current expenses of the state
government,” “maintenance of state institutions,” and “support of public
schools”—is preceded by the word “for.” That word “for” links each item back to
the qualifying phrase “laws making appropriations.” The exception applies only
to appropriations bills, and House Bill 1 is not one. See Doyle v. Tidball, 625
S.W.3d 459, 466 (Mo. banc 2021) (“Appropriations [bills] consist of both a
specific amount [appropriated] and a specific purpose.”).
1 The exceptions in Section 52(a) cover legislation that is effective at a time other
than “ninety days after the adjournment of the session . . . at which it was
enacted.” Mo. Const. art. III, § 29. This makes sense, as the purpose of the
referendum is to commit to the people the power to approve legislation that is not
already in effect.
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B.
The Referendum is Encompassed Within Missouri’s Legislative
Power
The Secretary nonetheless contends constitutional restrictions on
legislative authority are construed narrowly and the Court should rely on this
principle to simply ignore the unambiguous language of the Constitution’s
referendum provisions. Def. Tr. Br. at 12. But that premise is flawed. The
referendum is not a “limitation” on the legislature’s power. It is simply part of
Missouri’s legislative process.
The United States Supreme Court agrees. Reaffirming a century of
precedent, the Court said the following reasoning “commands our continued
respect”—that the “state legislature may not create congressional districts
independent of requirements imposed by the state constitution with respect to
the enactment of the laws.” 600 U.S. at 26.
And what might those requirements be? Those that are embraced by the
state legislative power, including “the referendum and the Governor’s veto.” Id.
This makes sense when you consider how the legislature gained its power in the
first instance. The people, when framing the Constitution, vested legislative
power “in a senate and house of representatives.” Mo. Const. art. III, § 1. At the
same time, the people reserved some of this power to themselves as a check on
the legislature. But it is still legislative authority. This is what the Supreme Court
of the United States recognized and what this Court must also conclude.
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C.
There Is No Clear Statement Doctrine in Missouri
Marching straight past the plain language of the Constitution without so
much as a sideways glance of acknowledgement, the Attorney General’s letter
accompanying the Secretary’s Certificate insists that there be a “clear statement”
specifically identifying redistricting bills as subject to the referendum. Stip. Ex. 5.
Missouri courts have never required a “clear statement” to authorize a
referendum on any issue, including the legislature’s redistricting power. It is the
other way around. Missouri’s Constitution has a clear statement that authorizes
the referendum on any act of the general assembly unless the State can point to a
clear statement that the referendum is not available—such as the limitations on
appropriations bills.
The Attorney General’s “opinion”—which apparently took ten months to
prepare—cites no authority for this upside-down proposition. That is because
none exists. The Attorney General’s invented “clear statement” rule has no basis
in caselaw. Rather, when the Constitution reserves referendum authority for “any
act of the general assembly,” it simply means what it says—“any act.” Mo. Const.
art. III, § 49.
Unable to find legal support for her invented rule, the Attorney General
argues that Chapter 116’s procedures are incompatible with referenda on
redistricting bills. Stip. Ex. 5. This argument fails on multiple levels.2 But more
2 Among other things, the Attorney General suggests Chapter 116 is incompatible
with redistricting bills because it gives the Secretary until the time when primary
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importantly, it is irrelevant. The Missouri Constitution controls, and statutes
cannot override constitutional rights. There is no canon of constitutional
construction that would allow a court to consider statutory schemes (created
about 40 years after the Constitution was adopted) to understand what the
drafters of the Constitution meant. It matters not what later legislatures may
have thought; the words of the Constitution control.
The Attorney General’s analysis of the statute also ignores the mandate on
how to treat statutes related to the people’s power. “Constitutional and statutory
provisions relative to initiative are liberally construed to make effective the
people’s reservation of that power.” Missourians to Protect the Initiative v.
Blunt, 799 S.W.2d 824, 827 (1990). If the statutes impeded the referendum—they
do not here—they would be unconstitutional. See Id. (“Statutes that place
impediments on the initiative power that are inconsistent with the reservation
found in the language of the constitution will be declared unconstitutional.” Id.)
These rules also apply to the referendum. United Labor Comm. of Mo. v.
Kirkpatrick, 572 S.W.2d 449, 454-55 (Mo. banc 1978). The legislature does not
have authority to “‘interfere with and impede’ the right of referendum” by taking
elections occur to certify the sufficiency of a referendum. Stip. Ex. 5. She ignores
that Chapter 116 does not require the Secretary to wait that long. And, as
discussed below, the record overwhelmingly establishes the Secretary could and
should have made his decision on the referendum many months ago. He
intentionally delayed his decision so he could claim it was too late to undo his
unlawful actions.
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steps to “make any referendum effort untenable.” No Bans on Choice, 638
S.W.3d at 491.
The Attorney General’s arguments about Chapter 116 miss the point. If the
Missouri Constitution subjects redistricting bills to the referendum power—and it
does—no statute can take that power away, even if the timing in those statutes
might make it awkward for state officials to comply with them.
D.
There is No Clear Statement Rule Relevant to Redistricting in
Federal Law
Straying even further from the plain language of the Missouri Constitution,
the Attorney General invokes the federal Elections Clause, claiming that
subjecting redistricting bills to the referendum power would violate federal law.
Stip. Ex. 5. But over a century of unbroken Supreme Court precedent forecloses
this argument entirely.
In Ohio ex rel. Davis v. Hildebrant, 241 U.S. 565 (1916), the Court squarely
addressed Ohio’s application of its referendum provision to a congressional
redistricting bill. Ohio’s constitutional provision—materially identical to
Missouri’s—applied to “any law enacted by the general assembly.” Id. at 566. It
contained no express statement that the referendum applied specifically to
congressional redistricting.
The people of Ohio used that power to reject a redistricting bill, and state
officials sought to invalidate the people’s vote on the theory that it violated the
Elections Clause. Id. at 566-67. The Court’s response was unequivocal:
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To the extent that the contention urges that to include the
referendum within state legislative power for the purpose
of apportionment is repugnant to § 4 of article 1 of the
Constitution and hence void . . . we again think the
contention is plainly without substance . . . .
Id. at 569 (emphasis added).
Then, in Smiley v. Holm, 285 U.S. 355 (1932), the Court similarly upheld
application of the gubernatorial veto to a congressional-redistricting act. It did
not require an express reference to veto authority over congressional-election
laws, or ask for any “clear statement.” See generally id. The Court expressly
reaffirmed its holding in Davis: “[T]he referendum provision of the state
Constitution, when applied to a law redistricting the state with a view to
representation in Congress, [i]s not unconstitutional.” Id. at 372.
The Secretary and Attorney General may wish the law had changed in the
past century. It has not. Just three years ago, in Moore v. Harper, the Supreme
Court reviewed the above line of cases and again confirmed that states may
subject redistricting bills to the referendum power and said nothing about any
need for a “clear statement” to do so. 600 U.S. 1 (2023).
The Supreme Court reiterated that it had already rejected the very
argument the Secretary is making here “as plainly without substance.” Id. at 23
(quotations omitted). The Court noted that “[n]owhere in the Federal
Constitution could [it] find provision of an attempt to endow the legislature of [a]
State with power to enact laws in any manner other than that in which the
constitution of the State has provided that laws shall be enacted.” Id. at 24
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(quotations omitted). “States . . . retain autonomy to establish their own
governmental processes.” Id. at 25 (quotations omitted). The bottom line: “A
state legislature may not create congressional districts independently of
requirements imposed by the state constitution with respect to the enactment of
laws.” Id. at 26 (quotations omitted; emphasis added). This includes the
referendum power. Id. at 26-27.
Where the United States Supreme Court has used a “clear statement rule,”
it has done so to limit federal intrusion on state authority, not the other way
around. In Bond v. United States, for example, the Court explained courts must
make “certain of Congress’s intent before finding that federal law overrides the
usual constitutional balance of federal and state powers.” 572 U.S. 844, 858
(2014) (quotations omitted). The Court required Congress to be explicit when it
sought to interfere in “several areas of traditional state responsibility,” such as
real estate, land use, and local crime. Id. The Court applied a similar requirement
in Sackett v. EPA, 598 U.S. 651 (2023), to “preserve the States’ primary authority
over land and water use.” Id. at 680 (quotations omitted).
What the Secretary and Attorney General propose is a complete reversal of
this principle. They argue that Missourians, when adopting their own
Constitution in 1945, should have used language clearer than the very same
language the Supreme Court had already held—over thirty years earlier in
Davis—was sufficient to subject redistricting bills to the referendum power. That
is not how clear-statement rules work. This Court should decline to invent one
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that would deprive Missouri courts of the power to interpret their own
Constitution.
The only Supreme Court decision the Attorney General cites to support her
desired “clear statement rule” is the particularly inapt United States v. Gradwell,
243 U.S. 476 (1917). That case involved several indictments charging conspiracies
to defraud the United States by bribing voters during a congressional election. Id.
The trial courts dismissed the indictments for failure to state a federal crime. Id.
at 479. The issue for the Supreme Court was the scope of (i) Congress’s power
over state elections and (ii) the particular statute in question. The Court
explained: “it has been [Congress’s] policy to leave such regulations almost
entirely to the states, whose representatives Congressmen are.” Id. at 482. The
Court simply noted that Congress had historically left control over state elections
to the states, and when it deviated from that policy, it did so clearly and
unmistakably. The Court refused to read a revenue law to criminalize election
activity:
With it thus clearly established that the policy of
Congress for so great a part of our constitutional life has
been, and now is, to leave the conduct of the election of
its members to state laws, administered by state officers,
and that whenever it has assumed to regulate such
elections it has done so by positive and clear statutes,
such as were enacted in 1870, it would be a strained and
unreasonable construction to apply to such elections this
§ 37, originally a law for the protection of the revenue,
and for now fifty years confined in its application to
‘Offenses against the Operations of the Government,’ as
distinguished from the processes by which men are
selected to conduct such operations.
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Id. at 485. Far from supporting the Secretary’s position, Gradwell confirms that
congressional elections remain subject to state control—including the
referendum power where it exists.
E.
Missourians Have Conducted Referenda on Congressional
Redistricting Plans
The historical record confirms Missouri voters have exercised this
referendum power over redistricting legislation—and Missouri courts have
consistently upheld their right to do so, without any concern about the potential
suspension of the legislation. Because the Constitution unambiguously subjects
congressional redistricting bills to the referendum power, it is no surprise that
Missouri voters have exercised this power before.
In 1922, Missouri voters blocked a congressional redistricting plan by
petitioning for a referendum, then defeated the plan by a decisive margin of 62%
to 38%. Stip Ex. 17; Stip Ex. 18. No one challenged this referendum in court.
Ten years later, in 1932, the Missouri Supreme Court cited the Supreme
Court’s Davis opinion for the proposition that the congressional “redistricting in
a state should be made by the laws of the state.” State ex rel. Carroll v. Becker, 45
S.W.2d 533, 536 (Mo. banc 1932), aff’d, 285 U.S. 380 (1932). The court noted
with approval that, in Ohio, “the referendum was a part of the lawmaking power
of the state, to be asserted in approving or disapproving a redistricting act by the
Legislature.” Id.; see also id. at 537 (holding that dividing states into
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congressional districts under the Elections Clause is a “legislative act” that must
be “accomplished by the laws of such states”).
Then, in 1952, the Supreme Court of Missouri decided State ex rel. Moore
v. Toberman, 250 S.W.2d 701 (Mo. banc 1952), concerning the timeliness of
referendum petitions voters filed against a congressional redistricting act. The
trial court concluded the act was “subject to the referendum provisions” in the
Missouri Constitution, and the Supreme Court affirmed. Id. at 703 (quoting the
trial court’s conclusions of law); see id. at 707. While that referendum effort failed
due to proponents’ failure to collect a sufficient number of signatures, the
Supreme Court did not remotely suggest redistricting acts are not subject to the
referendum power and, indeed, affirmed the trial court’s determination that they
are. See Stip. Ex. 19.
A decade later, in Preisler v. Hearnes, 362 S.W.2d 552 (Mo. banc 1962),
the Missouri Supreme Court issued a unanimous opinion rejecting a one-person,
one-vote challenge to a congressional redistricting act. Significantly, the Court
observed that “the people of this state have a remedy for even valid redistricting,
which they do not like, through our initiative and referendum provisions.” Id. at
557 (citing Mo. Const. art. III, § 49-53). This consistent line of authority confirms
what is obvious from the Constitution’s text: redistricting bills are subject to the
referendum.
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III.
The United States Constitution Does Not Bar Referendum on
Redistricting Bills
The Secretary’s federal constitutional arguments fail both on jurisdictional
and substantive grounds. The Attorney General argues that subjecting House Bill
1 to the referendum would violate the Elections Clause and the Guarantee Clause
of the United States Constitution. Stip. Ex. 5. Neither argument has merit. But
more fundamentally, neither is properly before this Court, because the Secretary
has no statutory authority to reject a referendum on these grounds.
A.
The Secretary May Only Assess the Constitutionality of a
Referendum for Compliance with the Missouri Constitutional
Requirements of Referendum
Chapter 116 defines the Secretary’s role in the referendum process. Once
signatures are submitted, the Secretary is directed to “examine the petition to
determine whether it complies with the Constitution of Missouri and with this
chapter.” § 116.120.1, RSMo. The statute gives no authority for either the
Secretary or the Attorney General to review, much less deny, the referendum
right on federal constitutional grounds.
The Courts have flatly rejected the idea. “The sufficiency determination the
Secretary of State is required to conduct plainly does not include whether an
initiative petition complies with the Federal Constitution.” Mo. Elec. Coops. v.
Kander, 497 S.W.3d 905, 920 (Mo. App. 2016). Indeed, “challenges to an
initiative petition which go beyond determining compliance with constitutional
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and statutory provisions pertaining to the required procedure and form of a
‘sufficient’ initiative petition are not ripe for pre-election judicial review.” Id.
This Court may not expand the powers in Chapter 116 any further than they
expressly extend. Laws implementing the referendum process “must be
subordinate to the constitutional provision and in furtherance of its purposes,
and must not . . . attempt to narrow or embarrass it.” No Bans on Choice, 638
S.W.3d at 489 (cleaned up).
Any broader reading of Chapter 116 would let the Secretary put his thumb
on the scale, blocking the people from voting on any measure he opposes. That is
not how Missouri’s referendum process works. The Secretary may campaign
against the referendum on his own time, but he may not use his office to prevent
Missouri citizens from exercising their constitutional rights.
Anything less would be a perversion of the referendum process. As the
Missouri Supreme Court has recognized:
[T]he initiative [and referendum] allows the public to
bypass their elected representatives and reserves direct
lawmaking power with the voters of the state. The
initiative [and referendum] is a tool for everyday,
ordinary citizens to override legislatures held in the thrall
of wealthy patrons. Initiative and referendum make it
possible for the people, by direct vote, to repeal bad laws
or enact beneficial measures that their representatives
refuse to consider.
Brown v. Carnahan, 370 S.W.3d 637, 673 (Mo. banc 2012). The Secretary’s effort
to claim judicial power for himself threatens to nullify these principles.
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Even setting aside this threshold problem, the Secretary’s federal
constitutional arguments fail on the merits. The United States Supreme Court has
already rejected them, repeatedly.
B.
The Elections Clause Does Not Bar Subjecting Redistricting Bills to
the Referendum
If it were appropriate to conduct a pre-election review of compliance with
the federal constitution, the analysis would be short. As explained in Section II.C,
the Supreme Court has rejected this argument repeatedly and emphatically—in
Davis, 241 U.S. at 569 (“plainly without substance”); Hawke v. Smith, 253 U.S.
221, 230 (1920); Smiley, 285 U.S. at 372; and Moore, 600 U.S. at 23-27. A
century of unbroken precedent forecloses the Secretary’s position.
The Attorney General’s letter seems to accept this precedent. See Stip. Ex.
5. To get around it, she argues the Elections Clause does not authorize a subset of
the electorate to vote to set aside congressional districts. This is, however, how
referenda work. A referendum suspends a law from going into effect so that the
voters of the state can decide whether to adopt the law or not. A referendum is
the process of “referring a state legislative act . . . to the people for final approval.”
Black’s Law Dictionary. Because the people, not the legislature, have final
approval, an act subject to the referendum is no law at all until the people vote on
it. Nothing in the Elections Clause prohibits this principle from applying to
congressional districts.
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C.
The Court Cannot Adjudicate Issues Concerning the Guarantee
Clause
The Attorney General’s invocation of the Guarantee Clause is equally
meritless. She vaguely asserts that allowing citizens to exercise their reserved
referendum power on redistricting bills would somehow cause Missouri to cease
having a “republican form of government.” Stip. Ex. 5. The implication is that the
referendum power itself is incompatible with republican government—a
proposition as remarkable as it is wrong.
In any event, the Supreme Court also rejected this argument more than a
century ago in Davis. In explaining the reasons why the challenge based on
Article I, Section 4 of the U.S. Constitution was “plainly without substance,” the
Court observed:
[That contention] must rest upon the assumption that to
include the referendum in the scope of the legislative
power is to introduce a virus which destroys that power,
which in effect annihilates representative government,
and causes a state where such condition exists to be not
republican in form, in violation of the guaranty of the
Constitution. Const. § 4, art. 4. But the proposition and
the argument disregard the settled rule that the question
of whether that guaranty of the Constitution has been
disregarded presents no justiciable controversy,
but involves the exercise by Congress of the authority
vested in it by the Constitution.
241 U.S. at 569 (emphasis added). The question is not justiciable and it has not
been for over a century.
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The question of what best effectuates a “republican form of government” is
committed to Congress, not the courts. See, e.g., Deer Park Indep. Sch. Dist. v.
Harris Cnty. Appraisal Dist., 132 F.3d 1095, 1099 (5th Cir. 1998) (“This claim is
not only incorrect, it is absurd. First of all, the Supreme Court has held that
challenges to Congressional action under the Guarantee Clause are not
justiciable.” (citing Baker v. Carr, 369 U.S. 186, 224 (1962))); Cnty. of Charles
Mix v. U.S. Dep't of Interior, 799 F. Supp. 2d 1027, 1037 (D.S.D. 2011), aff’d, 674
F.3d 898 (8th Cir. 2012) (“Claims under the Guarantee Clause usually are
considered political questions, and courts rarely find them justiciable.”). The
Supreme Court has also repeatedly made clear that redistricting is a legislative
act subject to all state-law restrictions on the exercise of legislative power,
including the referendum. Moore, 600 U.S. at 23-27. The Secretary’s Guarantee
Clause argument fails on both justiciability and the merits.
IV.
The Secretary’s Contention that it is Too Late for the Courts to
Grant Relief is Meritless and Barred by the Secretary’s Unclean
Hands
In the “opinion” attached to the Secretary’s Certificate, the Attorney
General offers various reasons why—even if House Bill 1 is subject to the
referendum (and it plainly is)—the Court should nonetheless require use of the
House Bill 1 map for the November general election. Stip. Ex. 5. These arguments
are meritless and, in any event, barred by the doctrine of unclean hands.
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The Missouri Constitution provides that when a bill is referred to the
people for referendum, it “shall take effect when approved by a majority of the
votes cast thereon, and not otherwise.” Mo. Const. art. III, § 52(b). As the
Supreme Court explained regarding this very measure:
If [] the December 9 referendum petition filing is
ultimately determined to be sufficient, article III, section
52(b) applies. In that case, because a “legal, sufficient,
and timely” referendum petition was filed on December
9—before HB 1 went into effect on December 11[, 2025]—
HB 1 did not take effect on December 11, HB 1 was
“referred to the people” as of December 9, [2025.] and
HB 1 “shall take effect when approved by a majority of the
votes cast thereon, and not otherwise.”
Maggard, 733 S.W.3d at 420. The Supreme Court could not have been clearer:
because Plaintiff’s referendum was and is sufficient, House Bill 1 has never been
the law. The Secretary’s wishful thinking cannot change this constitutional
reality, and his present arguments are nothing more than an attempt to benefit
from the “crisis” he created.
A.
The Secretary’s Arguments Are Barred by Unclean Hands
Even if this Court somehow had the authority to ignore what the Supreme
Court already said about the effect of sufficiency, the Court should reject all of the
Secretary’s arguments on this subject because they represent an attempt to gain
from his own wrongdoing. The Supreme Court told the Secretary in May—
months before the primary—what the consequences would be if the referendum
were deemed sufficient. Maggard, 733 S.W.3d at 420. Rather than faithfully
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doing his job, the Secretary intentionally delayed his decision until the last
minute to manufacture the very “exigency” he now invokes.
This is beyond dispute. The Secretary insisted for months that he intended
to wait until the last possible moment to issue a certification decision. Stip. Ex. 14;
Stip. Ex. 15; Stip. Ex. 16. He and the Attorney General began announcing this
strategy last October. Id. They publicly acknowledged this was a deliberate tactic
to force the House Bill 1 map on Missouri voters, observing that so long as the
status quo was the House Bill 1 map, delay worked in their favor. Id.
At the same time, the Secretary and Attorney General sought to have a
federal court bar Plaintiff from even turning in signatures. Stip. Ex. 6; Stip. Ex. 7.
They made the exact same constitutional arguments set out in the Attorney
General’s letter. Id. The federal court dismissed the case, observing that if the
Secretary did not want to count signatures, he could immediately deem the
referendum insufficient and the issue would be promptly resolved by Missouri
courts. Stip. Ex. 8. The Secretary then sought reconsideration, insisting the federal
court was egregiously wrong in its analysis. Stip. Ex. 9. When that motion was
denied, Stip. Ex. 10. , the Secretary (and other plaintiffs) did not file an appeal.
The events in federal court show there was no legitimate reason for the
Secretary to delay his certification decision. Later, he offered the excuse that he
needed time to validate the number of signatures submitted in support of the
referendum. Stip Ex. 10. Remarkably, the Secretary’s certification decision does
not even address the number of signatures. Stip. Ex. 5. There was no reason for
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the Secretary to have waited—other than his desire to later argue (as he is now
doing) that House Bill 1 must be used, even though it has never been the law.
The Supreme Court has rejected these tactics before. In Purcell v. Cape
Girardeau County Commission, 322 S.W.3d 522 (Mo. banc 2010), a county
commissioner induced his colleagues to conduct a closed meeting. He then
turned around and sued the Commission, claiming it violated the Sunshine Law
for doing exactly what he suggested. Id. at 523. The trial court rejected the claim
on the merits. Id.
The Supreme Court affirmed, but it skipped the merits and concluded the
commissioner’s requested relief was barred by his unclean hands. Id. at 524-25.
“A litigant with unclean hands generally is not entitled to equitable relief such as
an injunction or declaratory judgment.” Id. at 524. This doctrine is meant to
“prevent opportunistic behavior.” Id. “A party who participates in inequitable
activity regarding the very issue for which it seeks relief will be barred by its own
misconduct from receiving relief.” Id. (quotations omitted). The Court had no
trouble concluding the commissioner’s actions met the test. Id. “What is material
is not that the plaintiff’s hands are dirty, but that he dirties them in acquiring the
right he now asserts.” Karpierz v. Easley, 68 S.W.3d 565, 572 (Mo. App. W.D.
2002) (quotations omitted).
The Secretary’s hands are dirty. He dirtied them precisely so he could
make the arguments he is now advancing. Plaintiff seeks an injunction barring
the Secretary from further use of House Bill 1 pending the people’s vote. Pet. at 8.
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The Secretary’s arguments that it is “too late” for such relief are the product of his
own misconduct and are barred by the doctrine of unclean hands.
B.
The Fact that Redistricting Is Required in Response to a Census Has
Nothing to Do with the Situation Here
The Attorney General suggests the Court should ignore Article III, Section
52(b)’s command that legislation be suspended pending the outcome of a
referendum because it would interfere with the legislature’s ability to redistrict in
response to the decennial census. Stip. Ex. 5. She asserts that the Supreme
Court’s holding in Maggard “would have disastrous consequences.” Stip Ex. 5.
Setting aside that this Court lacks authority to change Maggard even if it would
have disastrous consequences, the Attorney General is wrong. Her arguments
might make sense if the legislature could redistrict only in response to a
decennial census. But the Supreme Court concluded—at her office’s urging—that
this is not the case. Luther v. Hoskins, 730 S.W.3d 567 (Mo. banc 2026). Where,
as here, the legislature draws new districts mid-cycle, there is no urgency to
implement those districts. Federal law does not require it.
And, when the legislature does redistrict in response to the decennial
census, it has tools at its disposal to ensure the new districts go into effect
promptly and Missouri remains in compliance with federal law: it can put a valid
emergency clause on the bill. That is exactly what the legislature did in 2022. See
H.B 2909, 101st Gen. Assemb. 2nd Reg. Sess. (2022). If there is truly an
emergency, the bill would not be subject to the referendum. See Mo. Const. art.
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III, § 49. House Bill 1 did not address an emergency, and no one claims it did.
Because House Bill 1 is simply a political exercise in mid-cycle redistricting and
was unnecessary to comply with the one-person, one-vote requirement, there is
no legal reason its districts must go into immediate effect. The Attorney General
cites none. This is not a basis to withhold relief.
C.
The Elections and Guarantee Clauses Are (Once Again) Irrelevant
Next, the Attorney General asserts the Elections Clause and Guarantee
Clause somehow require House Bill 1 to go into immediate effect. Stip. Ex. 5.
This is just a repackaging of her argument that those clauses prohibit subjecting a
redistricting bill to the referendum. For the reasons discussed above, those
arguments are meritless. The Supreme Court has repeatedly rejected them. And
issues relating to the Guarantee Clause are not even justiciable.3
The Attorney General complains it would violate the U.S. Constitution to
allow a referendum to suspend a law that has already been used to conduct the
primary election. As explained below, however, there is no constitutional
requirement to have a primary election in the first place. And the Secretary and
Attorney General are the ones who created this situation.
3 Also, in one of the few cases the Attorney General cites, the Supreme Court
made clear there is no single form of “republican government.” “No particular
government is designated as republican, neither is the exact form to be
guaranteed, in any manner especially designated.” Minor v. Happersett, 88 U.S.
162, 175 (1874).
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The federal court told the Secretary to resolve this issue back in December.
Stip. Ex. 8. The Supreme Court strongly encouraged him to do so in May.
Maggard, 733 S.W.3d 411. The Secretary could certainly have had these issues
resolved well before candidate filing even opened. And if the Secretary and his
allies truly believe Missourians will approve House Bill 1, the legislature could
have set a special election so that the map could be approved and then used in
November. Mo. Const. art. III, § 52(b) (“All elections on measures referred to the
people shall be had at the general state elections, except when the general
assembly shall order a special election.”). Having done none of those things, the
Secretary cannot now complain about the consequences of his own inaction.
Finally, the Attorney General asserts “Missourians have spoken
overwhelmingly” on House Bill 1 because it was enacted by the legislature with
comfortable margins. Stip. Ex. 5. The vote tally reflects nothing of the sort.
Missouri voters overwhelmingly rejected two other measures (Amendments 4
and 5) proposed by the legislature on the very day the Attorney General wrote her
letter. See https://enr.sos.mo.gov/.
D.
Purcell Does Not Apply Here; Missouri Has a Statute on Ballot
Changes
In his trial brief also raises the so-called “Purcell Principle” as an
impediment to relief. The Court should reject this argument. The principle
applies only in federal courts, and Missouri already has a statutory deadline for
ballot changes.
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The Purcell Principle is a rule that “federal courts ordinarily should not
enjoin a state’s election laws in the period close to an election.” Merrill v.
Milligan, 142 S. Ct. 879, 880 (2022) (Mem.) (Kavanaugh, J., concurring)
(emphasis added). It has no bearing on “the authority of state courts to apply
their own constitutions to election regulations,” but is instead limited to policing
“federal intrusion on state lawmaking processes.” Democratic Nat’l Comm. v.
Wis. State Legislature, 141 S. Ct. 28, 28 (2020) (Mem.) (Roberts, C.J.,
concurring). State courts have recognized Purcell has no application to them. See,
e.g., Matter of Harkenrider v. Hochul, 197 N.E.3d 437, 454 n.16 (N.Y. 2022);
Martin v. Simon, 6 N.W.3d 443, 451-52 (Minn. 2024); Democratic Senatorial
Campaign Comm. v. Pate, 950 N.W.2d 1, 15 (Iowa 2020) (Appel, J., concurring).
Applying Purcell here is particularly inappropriate. The legislature has
already decided when it is too late to make changes to ballots—there is a statute
governing that issue. Under Section 115.125, courts can make changes to ballots
until the eighth Tuesday before an election (here, September 8). Applying that
statute, Missouri courts have ordered changes up until the very last minute.4 See,
e.g., Coleman v. Ashcroft, 696 S.W.3d 347 (Mo. banc 2024) (placing abortion
question on ballot on day of deadline and warning against delays of the sort the
4 Also, Purcell is often invoked by federal courts where affording relief would
require a state legislature to draw new district boundaries when there is no time
to do so. That isn’t an issue here, because the 2022 boundaries are already in
legal effect and, indeed, have already been used to conduct congressional
elections.
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Secretary engaged in here). This case can and will be fully resolved before that
deadline.
Finally, the Secretary has previously conceded Purcell is irrelevant. In trial
court briefing in Maggard, the Secretary asserted: “The Purcell principle does
not override the Secretary’s and local election authorities’ statutory obligations to
review PNP’s referendum petition for legal sufficiency and to certify PNP’s
petition if it is legally sufficient.” Resp. Tr. Br. at 14 n.6 (Feb. 9, 2026) (Case No.
25AC-CC009120). That admission is fatal. This is a statutorily authorized action
for review of the very decision the Secretary concedes is not governed by Purcell.
E.
Hadley is Similarly Irrelevant
Nor does Hadley v. Junior College District of Metropolitan Kansas City,
460 S.W.2d 1 (Mo. banc 1970), help the Secretary. In Hadley, the Missouri
Supreme Court implemented a federal mandate after the U.S. Supreme Court
found Missouri’s junior college trustee elections violated the one-person-one-vote
requirement. Id. at 2. Because that mandate arrived mere days before the
candidate filing deadline—with absentee ballots already being printed and voting
machines being adjusted—the court allowed a single election to proceed under
the invalidated statute. Id. at 2–3.
Hadley did not announce any sort of bright-line rule on making changes to
boundaries close to an election. Rather, the Court balanced the equities based on
the facts before it—which undoubtedly included the relative importance of the
junior college trustee elections at issue—and concluded those facts did not
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warrant changes 32 days before an election. Id. That narrow remedial decision is
inapposite here.
Plaintiff asks this Court to exercise its statutory responsibility to review the
Secretary’s certification decision. See § 116.200, RSMo. If the Secretary’s decision
was improper, there is no prudential consideration prohibiting this Court from
reversing. Indeed, reversal is the Court’s statutory obligation. Further, Hadley’s
timing constraints arose from external judicial action—not from a litigant’s own
strategic delay. Here, the Secretary engineered the timing problem he now
invokes, ignoring repeated judicial encouragement to resolve this matter months
ago. See Maggard, 733 S.W.3d at 420 (warning that if Referendum was
sufficient, HB 1 “can only go into effect when approved by a majority of the votes
cast thereon”); see also Stip. Ex. 8.
Moreover, one-person-one-vote concerns required the court in Hadley to
restructure electoral machinery on an emergency basis; here, the Court need only
determine whether the referendum petition is sufficient and require the Secretary
to operate the election under whichever map is in effect. If the referendum
petition is deemed sufficient, the 2022 congressional map has always been in
effect. See Maggard, 733 S.W.3d at 420. And unlike in Hadley, the General
Assembly has already codified the relevant timing rule in Section 115.125, giving
the Court and the Secretary plenty of time to implement whichever map applies.
There will be no changes here the day before an election. The General Assembly
ensured that would never be the case.
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F.
The Secretary’s Contentions Regarding Article I, Section 2 of the U.S.
Constitution and UOCAVA Are Erroneous Because There Is No Need
to Run Another Primary
The Secretary also claims the Court cannot grant relief because doing so
would violate UOCAVA (52 U.S.C. §§ 20301, 20302) and Article I, Section 2 of
the U.S. Constitution. See Stip. Ex. 5. But both arguments rest on the same
mistaken premise: that following the dictates of the Supreme Court’s decision in
Maggard requires Missouri to run new primaries.5 No one is asking for that.
There is no party before the Court demanding such relief. And it is unnecessary.
There is no requirement that the same map that was used in the primary
must be used for the general election. Indeed, despite his lengthy trial brief, the
Secretary fails to identify a single case in which Missouri or federal courts have
ever said it is required. Instead, the Secretary cites various cases standing for the
unremarkable proposition that where primary elections are part of state election
law, the government cannot deprive minorities of the right to participate in such
elections. See United States v. Classic, 313 U.S.299 (1941); Smith v. Allwright,
321 U.S. 649 (1944). That makes sense, and is not at issue.
What does not make sense is the Secretary’s implicit assumption that the
same people who voted in primary elections must necessarily vote on the same
5 In the case of UOCAVA, the Secretary suggests that this could theoretically be
done, were there enough time to send out military and overseas ballots for a new
primary. Stip. Ex. 5.
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candidates at the general election. That never happens. Voters die. People turn
18. People are convicted of crimes and lose their right to vote. People move to
different districts. Some who did not vote in the primary choose to vote in the
general (and vice versa). There is no requirement that the same people who voted
in the primary must vote in the general election—such a requirement could not
possibly work.
On occasion, the identity of candidates changes between the primary and
the general election too. Because sometimes things happen, like a candidate
dying between the primary and the general. Missouri law reflects this reality.
Section 115.363 identifies circumstances under which a party nominating
committee can select a candidate for the general election. They include: death of a
candidate, disqualification of a candidate, and withdrawal of a candidate.
§ 115.363.3, RSMo. The law covers congressional districts. § 115.365.1(5), RSMo.
These statutes reflect that not only does the composition of voters change after a
primary, but sometimes candidates do as well. By the Secretary’s logic, however,
these common-sense solutions would all be unconstitutional because voters are
now being presented with candidates they did not vote for during the primary.
Also, the law does not require a candidate for Congress to live in the
district in which they seek to be elected. U.S. Const. art. I, § 2. No candidate will
be disqualified from holding office by virtue of using the 2022 boundaries. The
Secretary does not suggest otherwise. His insistence on using the House Bill 1
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boundaries during the primary—knowing full well what would happen if the
referendum was deemed sufficient—provides no basis to withhold relief now.
The Secretary also claims using different congressional boundaries during
the general election would somehow violate the Equal Protection Clause of the
Fourteenth Amendment. See Def. Tr. Br. at 46-48. But these arguments are even
less developed than the Secretary’s Election Clause arguments. He cites one
case—Gray v. Sanders, 372 U.S. 368 (1963)—to support this assertion. But Gray
simply held that when a state conducts primary elections it must comply with the
one-person-one-vote principle and cannot create districts that weight some
voters’ votes more than others. Id. The Secretary wholly fails to explain how using
the 2022 boundaries—which no one has ever claimed violate that legal
requirement—would raise such an issue.
The Secretary simply asserts it would be unfair to require voters to
consider different candidates at the general than they considered at the primary.
He should have thought about that before engaging in intentional delay. And, in
any event, that is not an equal protection issue. It isn’t a constitutional violation
of any sort. Again, voters are presented with different candidates than they
considered at the primary on a not-infrequent basis due to candidate deaths,
withdrawals, disqualifications, etc.
No one will be deprived of any rights if the 2022 boundaries are used.
Voters who cared to participate in the primaries had their votes counted. That
resulted in the nomination of a slate of candidates who may or may not appear on
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the general election ballot, for a variety of reasons. Anyone who is eligible and
wishes to vote in November will again have the opportunity to do so, and can help
decide which of the candidates running in their district will represent them.
V.
The Secretary Has Waived Any Argument that the Referendum
Lacks a Sufficient Number of Signatures and, In Any Event, It
Has More than Enough
Having addressed the Secretary’s constitutional arguments, the Court
should also note that the Secretary has waived any challenge to the sufficiency of
the signatures—and, in any event, the petition contains far more signatures than
required.
The Constitution requires that, for a referendum to be placed on the ballot,
it must contain signatures of five percent of voters in two-thirds of the state’s
congressional districts. Mo. Const. art. III, § 52(a). The Secretary may choose the
method by which to verify those signatures from the statutory options—random
sampling or a count of every signature—or he may rely on circulator affidavits.
See Maggard, 733 S.W. 3d at 416. Regardless of the method chosen, the people’s
referendum right cannot be defeated because the Secretary refuses to engage in
the verification process.
The Secretary sent the petition pages to the local election authorities to
verify the signatures. Progress reports of that verification process have been
posted on the Secretary’s website for months. On August 6, the Secretary
produced a final (not preliminary) report of the signature verification. Stip. Ex. 4.
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That report shows there are more than enough valid signatures supporting the
referendum from six of Missouri’s eight congressional districts. Id. Yet,
remarkably, the Secretary said nothing about the signature count in his certificate
of insufficiency—a telling omission.
To the extent the Secretary believed he could omit any signature count
from his certificate and later claim the petition lacks sufficient signatures, he is
mistaken. The statute requires signature verification and a certificate of
sufficiency or insufficiency to be completed “not later than 5:00 p.m. on the
thirteenth Tuesday prior to the general election or two weeks after the date the
election authority certifies the results of a petition verification . . . whichever is
later.” § 116.150.3, RSMo. That deadline has passed. The Secretary had his chance
to challenge the number of signatures and declined to do so. He cannot take a
second bite at the apple.
Any such challenge would also be futile. Based on the documentation
released by the Secretary of State’s office, the referendum petition contains more
than 160,000 valid signatures, as determined by the local election authorities,
spread across six of the state’s eight congressional districts. Stip. Ex. 4. This is
more than 45,000 signatures above the threshold necessary to qualify for the
ballot—a margin that forecloses any serious challenge to sufficiency on signature
grounds.
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VI.
Conclusion
The Secretary’s (and Attorney General’s) reasoning for declaring the
Referendum Petition insufficient are without merit. They are foreclosed by the
text of the Constitution, longstanding Missouri and U.S. Supreme Court
precedent, and basic common sense. This Court should, pursuant to Section
116.200, order the Secretary to reverse his decision of insufficiency, issue a
certificate of sufficiency, and place the Referendum Petition on the ballot for the
people to vote on in November. In addition, the Court should issue an injunction
barring the Secretary and anyone acting in concert with him from running the
November congressional election using the congressional district boundaries
found in House Bill 1.
Respectfully submitted,
STINSON LLP
/s/ Charles W. Hatfield
Charles W. Hatfield, No. 40363
Alexander C. Barrett, No. 68695
Alixandra S. Cossette, No. 68114
Greta M. Bax, No. 73354
230 W. McCarty Street
Jefferson City, Missouri 65101
Phone: (573) 636-6263
Fax: (573) 556-3632
chuck.hatfield@stinson.com
alexander.barrett@stinson.com
alix.cossette@stinson.com
greta.bax@stinson.com
ATTORNEYS FOR PLAINTIFF
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CERTIFICATE OF SERVICE
I hereby certify that on August 18, 2026, I electronically filed the foregoing
Plaintiff’s Suggestions in Opposition to Motion to Intervene with the Clerk of
Court using the Court’s e-filing system.
/s/ Charles W. Hatfield
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IN THE CIRCUIT COURT OF COLE COUNTY, MISSOURI
RICHARD VON GLAHN,
Plaintiff,
v.
DENNY HOSKINS, in his official
capacity,
Defendant.
)
)
)
)
)
)
)
)
)
)
)
Case No. 26AC-CC00440
JOINT STIPULATION OF FACTS AND EXHIBITS
The Parties stipulate to the admission of the following facts and exhibits. By
stipulating to these facts and exhibits, the Parties do not concede that such facts
and exhibits are relevant or necessary for the Court to resolve this matter. The
Parties have agreed not to object to the entry of these facts and exhibits into the
record, reserving objections to relevance only. Matters contained in exhibits but
not expressly discussed in a stipulation are part of the record and may be cited by
the Parties.
1.
Plaintiff Richard von Glahn is a Missouri citizen, resident of St. Louis
County, a taxpayer, and qualified voter in the State of Missouri.
2.
Defendant Denny Hoskins is the Secretary of State for the State of
Missouri.
3.
Intervenor Republican National Committee is the national
committee of the Republican Party as defined by 52 U.S.C. § 30101.
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4.
Intervenor National Republican Congressional Committee is the
national congressional committee of the Republican Party as defined by 52 U.S.C.
§ 30101(14).
5.
Intervenor Missouri Republican State Committee is the duly
established state committee for the Missouri Republican Party under Section
115.603, RSMo., and has been selected and serves in the role of representing and
acting for the Missouri Republican Party in the interim between party
conventions under Section 115.605, RSMo.
6.
Attached as Stipulated Exhibit 1 is a true and correct copy of
Referendum Petition 2026-R004.
7.
Attached as Stipulated Exhibit 2 is a true and correct copy of the
October 14, 2025 letter approving Referendum Petition 2026-R004 as to form.
8.
Attached as Stipulated Exhibit 3 is a true and correct copy of the
signature pages submitted to the local election authorities for Referendum
Petition 2026-R004.
9.
Attached as Stipulated Exhibit 4 is a true and correct copy of
Report PM-007 dated August 6, 2026 for Referendum Petition 2026-007.
10.
Attached as Stipulated Exhibit 5 is a true and correct copy of the
Certificate of Insufficiency for Referendum Petition 2026-R004.
11.
Attached as Stipulated Exhibit 6 is a true and correct copy of the
Complaint filed in Missouri General Assembly, et al., v. von Glahn, et al., Case
No. 4:25-cv-01535.
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12.
Attached as Stipulated Exhibit 7 is a true and correct copy of the
Motion for Preliminary Injunction filed in Missouri General Assembly, et al., v.
von Glahn, et al., Case No. 4:25-cv-01535.
13.
Attached as Stipulated Exhibit 8 is a true and correct copy of the
Memorandum and Order (Dec. 8, 2025) issued in Missouri General Assembly, et
al., v. von Glahn, et al., Case No. 4:25-cv-01535.
14.
Attached as Stipulated Exhibit 9 is a true and correct copy of the
State of Missouri’s Motion to Alter the Judgment and Memorandum in Support
filed in Missouri General Assembly, et al., v. von Glahn, et al., Case No. 4:25-cv01535.
15.
Attached as Stipulated Exhibit 10 is a true and correct copy of the
Memorandum and Order (May 11, 2026) issued in Missouri General Assembly, et
al., v. von Glahn, et al., Case No. 4:25-cv-01535.
16.
Attached as Stipulated Exhibit 11 is a true and correct copy of
Make Your Voice Heard: Missouri’s Initiative Petition Process.
17.
Attached as Stipulated Exhibit 12 is a true and correct copy of an
October 15, 2025 press release from the Secretary of State.
18.
Attached as Stipulated Exhibit 13 is a true and correct copy of an
October 16, 2025 press release from the Secretary of State.
19.
Attached as Stipulated Exhibit 14 is a true and correct copy of an
October 28, 2025 St. Louis Public Radio article titled “Missouri Republicans
learn that redrawing congressional lines isn’t so easy” by Jason Rosenbaum.
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20.
Attached as Stipulated Exhibit 15 is a true and correct copy of a
May 18, 2026 St. Louis Public Radio article titled “Group asks judge to force
Missouri secretary of state to decide redistricting referendum” by Jason
Rosenbaum.
21.
Attached as Stipulated Exhibit 16 is a true and correct copy of a
January 8, 2026 Kansas City Star article titled “Is Missouri GOP dragging out
redistricting cases? ‘Delay works in our favor’” by Kacen Bayless.
22.
Attached as Stipulated Exhibit 17 is a true and correct copy of the
1922 election results for Proposition 17.
23.
Attached as Stipulated Exhibit 18 are true and correct copies of
newspaper articles regarding the 1922 election on Proposition 17.
24.
Attached as Stipulated Exhibit 19 are true and correct copies of
newspaper articles regarding the attempted 1952 referendum election on
congressional redistricting.
25.
Attached as Stipulated Exhibit 20 is a true and correct copy of
House Bill 2909 (2022).
26.
Attached as Stipulated Exhibit 21 is a true and correct copy of the
affidavit of Brianna Lennon, executed August 13, 2026.
27.
Attached as Stipulated Exhibit 22 is a true and correct copy of
People Not Politicians’ and Richard von Glahn’s Motion to Expedite filed on April
1, 2026, in State ex rel. People Not Politicians, et al., v. Limbaugh, No.
WD88821.
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28.
Attached as Stipulated Exhibit 23 is a true and correct copy of
People Not Politicians’ and Richard von Glahn’s Suggestions in Support of
Petition for a Writ of Prohibition filed on April 1, 2026, in State ex rel. People Not
Politicians, et al., v. Limbaugh, No. WD88821.
29.
Attached as Stipulated Exhibit 24 is a true and correct copy of
Appellants’ Motion to Expedite filed on December 31, 2025, in Luther v. Hoskins,
No. SC101412.
30.
Attached as Stipulated Exhibit 25 is a true and correct copy of
Plaintiffs’ Suggestions in Opposition to a Continuance filed on December 15,
2025, in Wise v. State, No. 2516-CV29597, and in Healey v. State, No. 2516CV31273.
31.
Attached as Stipulated Exhibit 26 is a true and correct copy of
Plaintiffs’ Suggestions in Support of a Preliminary Injunction filed on January 14,
2026, in Maggard v. State, No. 25AC-CC09120.
32.
Attached as Stipulated Exhibit 27 is a true and correct copy of
Respondent’s Brief filed on February 9, 2026, in Luther v. Hoskins, No.
SC101412.
33.
Attached as Stipulated Exhibit 28 is a true and correct copy of the
affidavit of Tammy Brown, executed August 13, 2026.
34.
Attached as Stipulated Exhibit 29 is a true and correct copy of the
Amicus Brief of Brianna Lennon filed on April 10, 2026, in Maggard v. State, No.
SC101581.
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35.
Attached as Stipulated Exhibit 30 is a true and correct copy of the
Amicus Brief of Kurt Bahr et al. filed on April 28, 2026, in Maggard v. State, No.
SC101581.
36.
Attached as Stipulated Exhibit 31 is a true and correct copy of the
transcript of the third day of trial, February 19, 2026, in Wise v. State, No. 2516CV29597, and in Healey v. State, No. 2516-CV31273.
37.
Attached as Stipulated Exhibit 32 is a true and correct copy of a
September 15, 2025 article by Mathew Pilger in the Missouri Independent titled
“Missouri’s New Congressional Map Could Complicate Midterm Voting Clerks
Warn.” Within Stipulated Exhibit 32 is a true, correct, and complete
transcription of an August 27, 2025 letter sent by Sherry Parks on behalf of the
Missouri Association of County Clerks and Election Authorities to Jonathan
Patterson, Speaker of the Missouri House of Representatives.
38.
Attached as Stipulated Exhibit 33 is a true and correct copy of an
August 4, 2026 article by Jen Rice and Yunior Rivas in Democracy Docket titled
“Missouri blocks anti-gerrymander referendum from November ballot in attempt
to silence voters.”
39.
Attached as Stipulated Exhibit 34 is a true and correct copy of a
March 27, 2026 article by Jen Rice in Democracy Docket titled “GOP derails bid
to stop Missouri gerrymander for 2026.”
40.
Attached as Stipulated Exhibit 35 is a true and correct copy of the
affidavit of Mike Ambrosini, executed August 13, 2026.
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41.
Attached as Stipulated Exhibit 36 is a true and correct copy of the
affidavit of Miles Ross, executed August 14, 2026.
42.
Attached as Stipulated Exhibit 37 is a true and correct copy of
Merrill Weber executed August 17, 2026.
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Respectfully submitted,
CATHERINE L. HANAWAY
ATTORNEY GENERAL
/s/ Louis J. Capozzi III
Louis J. Capozzi III, #77756
Solicitor General
J. Michael Patton, #76490
Deputy Solicitor General
Office of the Attorney General
815 Olive Street, Suite 200
St. Louis, MO 63101
Tel. (573) 645-9662
Fax (573) 751-0774
Louis.Capozzi@ago.mo.gov
Michael.Patton@ago.mo.gov
STINSON LLP
/s/ Alixandra S. Cossette
Charles W. Hatfield, No. 40363
Alexander C. Barrett, No. 68695
Alixandra S. Cossette, No. 68114
Greta M. Bax, No. 73354
230 W. McCarty Street
Jefferson City, Missouri 65101
Phone: (573) 636-6263
Fax: (573) 556-3632
chuck.hatfield@stinson.com
alexander.barrett@stinson.com
alix.cossette@stinson.com
greta.bax@stinson.com
Counsel for Secretary
Hoskins
ATTORNEYS FOR PLAINTIFF
ELLINGER BELL LLC
JONES DAY
By: /s/ Marc H. Ellinger
Marc H. Ellinger, #40828
Stephanie S. Bell, #61855
Cole D. Bradbury, #62760
308 East High Street, Suite 300
Jefferson City, MO 65101
Telephone: (573) 750-4100
Facsimile: (314) 334-0450
E-mail:
mellinger@ellingerlaw.com
Email: sbell@ellingerlaw.com
Email:cbradbury@ellingerlaw.com
By: /s/ John M. Gore
John M. Gore (pro hac
forthcoming)
51 Louisiana Ave., NW
Washington, DC 20001
Telephone: (202) 879-3930
Facsimile: (202) 626-1700
E-mail: jmgore@jonesday.com
Attorneys for Intervenors
Attorneys for Intervenors
8
vice
CERTIFICATE OF SERVICE
I hereby certify that on August 18, 2026, I electronically filed the foregoing
Plaintiff’s Suggestions in Opposition to Motion to Intervene with the Clerk of Court
using the Court’s e-filing system.
/s/ Alixandra S. Cossette
Attorney for Plaintiff
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