Saved copy of
Stay application appendix, volume 2
Office of the Missouri Attorney General · 2026-09-04
The saved file is a PDF document of 12.5 MB. What follows is the text taken from it, which is the text the story quotes.
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. II 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
408a
Stipulated Exhibit 1
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
SC101805 Appeal Document Number 23 Page 1
409a
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
SC101805 Appeal Document Number 23 Page 2
410a
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
SC101805 Appeal Document Number 23 Page 3
411a
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
SC101805 Appeal Document Number 23 Page 4
412a
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
SC101805 Appeal Document Number 23 Page 5
413a
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
SC101805 Appeal Document Number 23 Page 6
414a
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
SC101805 Appeal Document Number 23 Page 7
415a
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
SC101805 Appeal Document Number 23 Page 8
416a
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
SC101805 Appeal Document Number 23 Page 9
417a
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
SC101805 Appeal Document Number 23 Page 10
418a
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
SC101805 Appeal Document Number 23 Page 11
419a
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
SC101805 Appeal Document Number 23 Page 12
420a
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
SC101805 Appeal Document Number 23 Page 13
421a
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
SC101805 Appeal Document Number 23 Page 14
422a
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
SC101805 Appeal Document Number 23 Page 15
423a
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
SC101805 Appeal Document Number 23 Page 16
424a
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
SC101805 Appeal Document Number 23 Page 17
425a
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
SC101805 Appeal Document Number 23 Page 18
426a
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
SC101805 Appeal Document Number 23 Page 19
427a
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
SC101805 Appeal Document Number 23 Page 20
428a
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
SC101805 Appeal Document Number 23 Page 21
429a
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
SC101805 Appeal Document Number 23 Page 22
430a
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
SC101805 Appeal Document Number 23 Page 23
431a
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
SC101805 Appeal Document Number 23 Page 24
432a
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
SC101805 Appeal Document Number 23 Page 25
433a
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
SC101805 Appeal Document Number 23 Page 26
434a
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
SC101805 Appeal Document Number 23 Page 27
435a
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
SC101805 Appeal Document Number 23 Page 28
436a
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
SC101805 Appeal Document Number 23 Page 29
437a
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
SC101805 Appeal Document Number 23 Page 30
438a
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
SC101805 Appeal Document Number 23 Page 31
439a
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
SC101805 Appeal Document Number 23 Page 32
440a
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
SC101805 Appeal Document Number 23 Page 33
441a
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
SC101805 Appeal Document Number 23 Page 34
442a
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
SC101805 Appeal Document Number 23 Page 35
443a
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
SC101805 Appeal Document Number 23 Page 36
444a
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
SC101805 Appeal Document Number 23 Page 37
445a
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
SC101805 Appeal Document Number 23 Page 38
446a
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
SC101805 Appeal Document Number 23 Page 39
447a
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
SC101805 Appeal Document Number 23 Page 40
448a
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
SC101805 Appeal Document Number 23 Page 41
449a
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
SC101805 Appeal Document Number 23 Page 42
450a
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
SC101805 Appeal Document Number 23 Page 43
451a
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
SC101805 Appeal Document Number 23 Page 44
452a
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
SC101805 Appeal Document Number 23 Page 45
453a
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
SC101805 Appeal Document Number 23 Page 46
454a
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
SC101805 Appeal Document Number 23 Page 47
455a
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
SC101805 Appeal Document Number 23 Page 48
456a
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
SC101805 Appeal Document Number 23 Page 49
457a
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
SC101805 Appeal Document Number 23 Page 50
458a
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
SC101805 Appeal Document Number 23 Page 51
459a
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
SC101805 Appeal Document Number 23 Page 52
460a
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
SC101805 Appeal Document Number 23 Page 53
461a
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
SC101805 Appeal Document Number 23 Page 54
462a
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
SC101805 Appeal Document Number 23 Page 55
463a
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
SC101805 Appeal Document Number 23 Page 56
464a
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
SC101805 Appeal Document Number 23 Page 57
465a
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
SC101805 Appeal Document Number 23 Page 58
466a
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
SC101805 Appeal Document Number 23 Page 59
467a
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
SC101805 Appeal Document Number 23 Page 60
468a
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
SC101805 Appeal Document Number 23 Page 61
469a
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
SC101805 Appeal Document Number 23 Page 62
470a
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
SC101805 Appeal Document Number 23 Page 63
471a
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
SC101805 Appeal Document Number 23 Page 64
472a
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
SC101805 Appeal Document Number 23 Page 65
473a
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
SC101805 Appeal Document Number 23 Page 66
474a
Stipulated Exhibit 2
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
SC101805 Appeal Document Number 24 Page 1
475a
26AC-CC00248
Electronically Filed - Cole
COLECircuit
CIRCUIT
- May
- 18,
August
2026
18,- 2026
02:24-PM
10:09 AM
SC101805 Appeal Document Number 24 Page 2
476a
Electronically Filed - Cole
COLECircuit
CIRCUIT
- May
- 18,
August
2026
18,- 2026
02:24-PM
10:09 AM
SC101805 Appeal Document Number 24 Page 3
Stipulated Exhibit 3
(Submitted via USB Drive to
Court)
CORE/3535149.0002/248814571.1
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
477a
SC101805 Appeal Document Number 25 Page 1
478a
Stipulated Exhibit 4
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
SC101805 Appeal Document Number 26 Page 1
Abbreviations and Denotation:
●
●
●
●
NR = not registered
WA = wrong address
WS = wrong signature
Counties with split congressional districts will show NR voters in their
first congressional district.
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
479a
SC101805 Appeal Document Number 26 Page 2
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
Adair County
U.S. Representative District 6
1. Number of Signatures found valid as "R"
166
2. Number of signatures found valid as "RDA"
6
3. Total Number of Valid Signatures (add 1 and 2)
172
4. Number of Signatures found invalid as "NR"
5
5. Number of Signatures found invalid as "WA"
2
6. Number of Signatures found invalid as "WS"
0
7. Total Number of Invalid Signatures (add 4, 5 and 6)
7
8. Total number of duplicate signatures
1
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
180
Page 1 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
480a
SC101805 Appeal Document Number 26 Page 3
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
Andrew County
U.S. Representative District 6
1. Number of Signatures found valid as "R"
65
2. Number of signatures found valid as "RDA"
2
3. Total Number of Valid Signatures (add 1 and 2)
67
4. Number of Signatures found invalid as "NR"
5
5. Number of Signatures found invalid as "WA"
0
6. Number of Signatures found invalid as "WS"
0
7. Total Number of Invalid Signatures (add 4, 5 and 6)
5
8. Total number of duplicate signatures
1
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
73
Page 2 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
481a
SC101805 Appeal Document Number 26 Page 4
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
Atchison County
U.S. Representative District 6
1. Number of Signatures found valid as "R"
45
2. Number of signatures found valid as "RDA"
0
3. Total Number of Valid Signatures (add 1 and 2)
45
4. Number of Signatures found invalid as "NR"
1
5. Number of Signatures found invalid as "WA"
0
6. Number of Signatures found invalid as "WS"
0
7. Total Number of Invalid Signatures (add 4, 5 and 6)
1
8. Total number of duplicate signatures
1
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
47
Page 3 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
482a
SC101805 Appeal Document Number 26 Page 5
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
Audrain County
U.S. Representative District 6
1. Number of Signatures found valid as "R"
256
2. Number of signatures found valid as "RDA"
21
3. Total Number of Valid Signatures (add 1 and 2)
277
4. Number of Signatures found invalid as "NR"
53
5. Number of Signatures found invalid as "WA"
0
6. Number of Signatures found invalid as "WS"
4
7. Total Number of Invalid Signatures (add 4, 5 and 6)
57
8. Total number of duplicate signatures
1
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
335
Page 4 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
483a
SC101805 Appeal Document Number 26 Page 6
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
Barry County
U.S. Representative District 7
1. Number of Signatures found valid as "R"
365
2. Number of signatures found valid as "RDA"
12
3. Total Number of Valid Signatures (add 1 and 2)
377
4. Number of Signatures found invalid as "NR"
68
5. Number of Signatures found invalid as "WA"
3
6. Number of Signatures found invalid as "WS"
17
7. Total Number of Invalid Signatures (add 4, 5 and 6)
88
8. Total number of duplicate signatures
0
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
465
Page 5 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
484a
SC101805 Appeal Document Number 26 Page 7
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
Barton County
U.S. Representative District 4
1. Number of Signatures found valid as "R"
118
2. Number of signatures found valid as "RDA"
2
3. Total Number of Valid Signatures (add 1 and 2)
120
4. Number of Signatures found invalid as "NR"
14
5. Number of Signatures found invalid as "WA"
3
6. Number of Signatures found invalid as "WS"
4
7. Total Number of Invalid Signatures (add 4, 5 and 6)
21
8. Total number of duplicate signatures
1
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
142
Page 6 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
485a
SC101805 Appeal Document Number 26 Page 8
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
Bates County
U.S. Representative District 4
1. Number of Signatures found valid as "R"
139
2. Number of signatures found valid as "RDA"
5
3. Total Number of Valid Signatures (add 1 and 2)
144
4. Number of Signatures found invalid as "NR"
13
5. Number of Signatures found invalid as "WA"
2
6. Number of Signatures found invalid as "WS"
4
7. Total Number of Invalid Signatures (add 4, 5 and 6)
19
8. Total number of duplicate signatures
2
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
165
Page 7 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
486a
SC101805 Appeal Document Number 26 Page 9
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
Benton County
U.S. Representative District 4
1. Number of Signatures found valid as "R"
200
2. Number of signatures found valid as "RDA"
2
3. Total Number of Valid Signatures (add 1 and 2)
202
4. Number of Signatures found invalid as "NR"
16
5. Number of Signatures found invalid as "WA"
1
6. Number of Signatures found invalid as "WS"
12
7. Total Number of Invalid Signatures (add 4, 5 and 6)
29
8. Total number of duplicate signatures
1
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
232
Page 8 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
487a
SC101805 Appeal Document Number 26 Page 10
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
Bollinger County
U.S. Representative District 8
1. Number of Signatures found valid as "R"
0
2. Number of signatures found valid as "RDA"
0
3. Total Number of Valid Signatures (add 1 and 2)
0
4. Number of Signatures found invalid as "NR"
0
5. Number of Signatures found invalid as "WA"
0
6. Number of Signatures found invalid as "WS"
0
7. Total Number of Invalid Signatures (add 4, 5 and 6)
0
8. Total number of duplicate signatures
0
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
0
Page 9 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
488a
SC101805 Appeal Document Number 26 Page 11
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
Boone County
U.S. Representative District 3
1. Number of Signatures found valid as "R"
6861
2. Number of signatures found valid as "RDA"
557
3. Total Number of Valid Signatures (add 1 and 2)
7418
4. Number of Signatures found invalid as "NR"
1679
5. Number of Signatures found invalid as "WA"
251
6. Number of Signatures found invalid as "WS"
29
7. Total Number of Invalid Signatures (add 4, 5 and 6)
1959
8. Total number of duplicate signatures
322
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
9699
U.S. Representative District 4
1. Number of Signatures found valid as "R"
7735
2. Number of signatures found valid as "RDA"
562
3. Total Number of Valid Signatures (add 1 and 2)
8297
4. Number of Signatures found invalid as "NR"
0
5. Number of Signatures found invalid as "WA"
0
6. Number of Signatures found invalid as "WS"
31
7. Total Number of Invalid Signatures (add 4, 5 and 6)
31
8. Total number of duplicate signatures
532
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
8860
Page 10 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
489a
SC101805 Appeal Document Number 26 Page 12
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
Buchanan County
U.S. Representative District 6
1. Number of Signatures found valid as "R"
425
2. Number of signatures found valid as "RDA"
12
3. Total Number of Valid Signatures (add 1 and 2)
437
4. Number of Signatures found invalid as "NR"
27
5. Number of Signatures found invalid as "WA"
2
6. Number of Signatures found invalid as "WS"
4
7. Total Number of Invalid Signatures (add 4, 5 and 6)
33
8. Total number of duplicate signatures
18
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
488
Page 11 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
490a
SC101805 Appeal Document Number 26 Page 13
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
Butler County
U.S. Representative District 8
1. Number of Signatures found valid as "R"
0
2. Number of signatures found valid as "RDA"
0
3. Total Number of Valid Signatures (add 1 and 2)
0
4. Number of Signatures found invalid as "NR"
0
5. Number of Signatures found invalid as "WA"
0
6. Number of Signatures found invalid as "WS"
0
7. Total Number of Invalid Signatures (add 4, 5 and 6)
0
8. Total number of duplicate signatures
0
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
0
Page 12 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
491a
SC101805 Appeal Document Number 26 Page 14
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
Caldwell County
U.S. Representative District 6
1. Number of Signatures found valid as "R"
34
2. Number of signatures found valid as "RDA"
0
3. Total Number of Valid Signatures (add 1 and 2)
34
4. Number of Signatures found invalid as "NR"
6
5. Number of Signatures found invalid as "WA"
0
6. Number of Signatures found invalid as "WS"
1
7. Total Number of Invalid Signatures (add 4, 5 and 6)
7
8. Total number of duplicate signatures
1
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
42
Page 13 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
492a
SC101805 Appeal Document Number 26 Page 15
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
Callaway County
U.S. Representative District 3
1. Number of Signatures found valid as "R"
753
2. Number of signatures found valid as "RDA"
3
3. Total Number of Valid Signatures (add 1 and 2)
756
4. Number of Signatures found invalid as "NR"
238
5. Number of Signatures found invalid as "WA"
0
6. Number of Signatures found invalid as "WS"
14
7. Total Number of Invalid Signatures (add 4, 5 and 6)
252
8. Total number of duplicate signatures
19
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
1027
Page 14 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
493a
SC101805 Appeal Document Number 26 Page 16
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
Camden County
U.S. Representative District 3
1. Number of Signatures found valid as "R"
90
2. Number of signatures found valid as "RDA"
3
3. Total Number of Valid Signatures (add 1 and 2)
93
4. Number of Signatures found invalid as "NR"
35
5. Number of Signatures found invalid as "WA"
1
6. Number of Signatures found invalid as "WS"
1
7. Total Number of Invalid Signatures (add 4, 5 and 6)
37
8. Total number of duplicate signatures
0
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
130
U.S. Representative District 4
1. Number of Signatures found valid as "R"
242
2. Number of signatures found valid as "RDA"
4
3. Total Number of Valid Signatures (add 1 and 2)
246
4. Number of Signatures found invalid as "NR"
0
5. Number of Signatures found invalid as "WA"
0
6. Number of Signatures found invalid as "WS"
7
7. Total Number of Invalid Signatures (add 4, 5 and 6)
7
8. Total number of duplicate signatures
2
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
255
Page 15 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
494a
SC101805 Appeal Document Number 26 Page 17
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
Cape Girardeau County
U.S. Representative District 8
1. Number of Signatures found valid as "R"
0
2. Number of signatures found valid as "RDA"
0
3. Total Number of Valid Signatures (add 1 and 2)
0
4. Number of Signatures found invalid as "NR"
0
5. Number of Signatures found invalid as "WA"
0
6. Number of Signatures found invalid as "WS"
0
7. Total Number of Invalid Signatures (add 4, 5 and 6)
0
8. Total number of duplicate signatures
0
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
0
Page 16 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
495a
SC101805 Appeal Document Number 26 Page 18
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
Carroll County
U.S. Representative District 6
1. Number of Signatures found valid as "R"
32
2. Number of signatures found valid as "RDA"
1
3. Total Number of Valid Signatures (add 1 and 2)
33
4. Number of Signatures found invalid as "NR"
3
5. Number of Signatures found invalid as "WA"
0
6. Number of Signatures found invalid as "WS"
0
7. Total Number of Invalid Signatures (add 4, 5 and 6)
3
8. Total number of duplicate signatures
5
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
41
Page 17 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
496a
SC101805 Appeal Document Number 26 Page 19
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
Carter County
U.S. Representative District 8
1. Number of Signatures found valid as "R"
0
2. Number of signatures found valid as "RDA"
0
3. Total Number of Valid Signatures (add 1 and 2)
0
4. Number of Signatures found invalid as "NR"
0
5. Number of Signatures found invalid as "WA"
0
6. Number of Signatures found invalid as "WS"
0
7. Total Number of Invalid Signatures (add 4, 5 and 6)
0
8. Total number of duplicate signatures
0
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
0
Page 18 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
497a
SC101805 Appeal Document Number 26 Page 20
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
Cass County
U.S. Representative District 4
1. Number of Signatures found valid as "R"
4137
2. Number of signatures found valid as "RDA"
166
3. Total Number of Valid Signatures (add 1 and 2)
4303
4. Number of Signatures found invalid as "NR"
691
5. Number of Signatures found invalid as "WA"
8
6. Number of Signatures found invalid as "WS"
175
7. Total Number of Invalid Signatures (add 4, 5 and 6)
874
8. Total number of duplicate signatures
85
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
5262
Page 19 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
498a
SC101805 Appeal Document Number 26 Page 21
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
Cedar County
U.S. Representative District 4
1. Number of Signatures found valid as "R"
123
2. Number of signatures found valid as "RDA"
2
3. Total Number of Valid Signatures (add 1 and 2)
125
4. Number of Signatures found invalid as "NR"
11
5. Number of Signatures found invalid as "WA"
12
6. Number of Signatures found invalid as "WS"
8
7. Total Number of Invalid Signatures (add 4, 5 and 6)
31
8. Total number of duplicate signatures
2
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
158
Page 20 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
499a
SC101805 Appeal Document Number 26 Page 22
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
Chariton County
U.S. Representative District 6
1. Number of Signatures found valid as "R"
36
2. Number of signatures found valid as "RDA"
0
3. Total Number of Valid Signatures (add 1 and 2)
36
4. Number of Signatures found invalid as "NR"
3
5. Number of Signatures found invalid as "WA"
0
6. Number of Signatures found invalid as "WS"
3
7. Total Number of Invalid Signatures (add 4, 5 and 6)
6
8. Total number of duplicate signatures
0
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
42
Page 21 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
500a
SC101805 Appeal Document Number 26 Page 23
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
Christian County
U.S. Representative District 7
1. Number of Signatures found valid as "R"
1819
2. Number of signatures found valid as "RDA"
72
3. Total Number of Valid Signatures (add 1 and 2)
1891
4. Number of Signatures found invalid as "NR"
220
5. Number of Signatures found invalid as "WA"
27
6. Number of Signatures found invalid as "WS"
39
7. Total Number of Invalid Signatures (add 4, 5 and 6)
286
8. Total number of duplicate signatures
34
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
2211
Page 22 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
501a
SC101805 Appeal Document Number 26 Page 24
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
Clark County
U.S. Representative District 6
1. Number of Signatures found valid as "R"
0
2. Number of signatures found valid as "RDA"
0
3. Total Number of Valid Signatures (add 1 and 2)
0
4. Number of Signatures found invalid as "NR"
1
5. Number of Signatures found invalid as "WA"
0
6. Number of Signatures found invalid as "WS"
0
7. Total Number of Invalid Signatures (add 4, 5 and 6)
1
8. Total number of duplicate signatures
0
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
1
Page 23 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
502a
SC101805 Appeal Document Number 26 Page 25
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
Clay County
U.S. Representative District 5
1. Number of Signatures found valid as "R"
1819
2. Number of signatures found valid as "RDA"
58
3. Total Number of Valid Signatures (add 1 and 2)
1877
4. Number of Signatures found invalid as "NR"
158
5. Number of Signatures found invalid as "WA"
47
6. Number of Signatures found invalid as "WS"
57
7. Total Number of Invalid Signatures (add 4, 5 and 6)
262
8. Total number of duplicate signatures
39
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
2178
U.S. Representative District 6
1. Number of Signatures found valid as "R"
1348
2. Number of signatures found valid as "RDA"
39
3. Total Number of Valid Signatures (add 1 and 2)
1387
4. Number of Signatures found invalid as "NR"
0
5. Number of Signatures found invalid as "WA"
0
6. Number of Signatures found invalid as "WS"
54
7. Total Number of Invalid Signatures (add 4, 5 and 6)
54
8. Total number of duplicate signatures
21
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
1462
Page 24 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
503a
SC101805 Appeal Document Number 26 Page 26
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
Clinton County
U.S. Representative District 6
1. Number of Signatures found valid as "R"
97
2. Number of signatures found valid as "RDA"
0
3. Total Number of Valid Signatures (add 1 and 2)
97
4. Number of Signatures found invalid as "NR"
8
5. Number of Signatures found invalid as "WA"
0
6. Number of Signatures found invalid as "WS"
0
7. Total Number of Invalid Signatures (add 4, 5 and 6)
8
8. Total number of duplicate signatures
1
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
106
Page 25 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
504a
SC101805 Appeal Document Number 26 Page 27
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
Cole County
U.S. Representative District 3
1. Number of Signatures found valid as "R"
2557
2. Number of signatures found valid as "RDA"
118
3. Total Number of Valid Signatures (add 1 and 2)
2675
4. Number of Signatures found invalid as "NR"
422
5. Number of Signatures found invalid as "WA"
52
6. Number of Signatures found invalid as "WS"
57
7. Total Number of Invalid Signatures (add 4, 5 and 6)
531
8. Total number of duplicate signatures
93
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
3299
Page 26 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
505a
SC101805 Appeal Document Number 26 Page 28
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
Cooper County
U.S. Representative District 3
1. Number of Signatures found valid as "R"
448
2. Number of signatures found valid as "RDA"
30
3. Total Number of Valid Signatures (add 1 and 2)
478
4. Number of Signatures found invalid as "NR"
72
5. Number of Signatures found invalid as "WA"
13
6. Number of Signatures found invalid as "WS"
7
7. Total Number of Invalid Signatures (add 4, 5 and 6)
92
8. Total number of duplicate signatures
14
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
584
Page 27 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
506a
SC101805 Appeal Document Number 26 Page 29
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
Crawford County
U.S. Representative District 3
1. Number of Signatures found valid as "R"
138
2. Number of signatures found valid as "RDA"
4
3. Total Number of Valid Signatures (add 1 and 2)
142
4. Number of Signatures found invalid as "NR"
14
5. Number of Signatures found invalid as "WA"
1
6. Number of Signatures found invalid as "WS"
19
7. Total Number of Invalid Signatures (add 4, 5 and 6)
34
8. Total number of duplicate signatures
1
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
177
Page 28 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
507a
SC101805 Appeal Document Number 26 Page 30
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
Dade County
U.S. Representative District 4
1. Number of Signatures found valid as "R"
64
2. Number of signatures found valid as "RDA"
8
3. Total Number of Valid Signatures (add 1 and 2)
72
4. Number of Signatures found invalid as "NR"
24
5. Number of Signatures found invalid as "WA"
0
6. Number of Signatures found invalid as "WS"
1
7. Total Number of Invalid Signatures (add 4, 5 and 6)
25
8. Total number of duplicate signatures
0
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
97
Page 29 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
508a
SC101805 Appeal Document Number 26 Page 31
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
Dallas County
U.S. Representative District 4
1. Number of Signatures found valid as "R"
144
2. Number of signatures found valid as "RDA"
0
3. Total Number of Valid Signatures (add 1 and 2)
144
4. Number of Signatures found invalid as "NR"
49
5. Number of Signatures found invalid as "WA"
2
6. Number of Signatures found invalid as "WS"
19
7. Total Number of Invalid Signatures (add 4, 5 and 6)
70
8. Total number of duplicate signatures
1
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
215
Page 30 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
509a
SC101805 Appeal Document Number 26 Page 32
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
Daviess County
U.S. Representative District 6
1. Number of Signatures found valid as "R"
60
2. Number of signatures found valid as "RDA"
0
3. Total Number of Valid Signatures (add 1 and 2)
60
4. Number of Signatures found invalid as "NR"
1
5. Number of Signatures found invalid as "WA"
3
6. Number of Signatures found invalid as "WS"
4
7. Total Number of Invalid Signatures (add 4, 5 and 6)
8
8. Total number of duplicate signatures
2
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
70
Page 31 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
510a
SC101805 Appeal Document Number 26 Page 33
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
De Kalb County
U.S. Representative District 6
1. Number of Signatures found valid as "R"
14
2. Number of signatures found valid as "RDA"
0
3. Total Number of Valid Signatures (add 1 and 2)
14
4. Number of Signatures found invalid as "NR"
9
5. Number of Signatures found invalid as "WA"
0
6. Number of Signatures found invalid as "WS"
0
7. Total Number of Invalid Signatures (add 4, 5 and 6)
9
8. Total number of duplicate signatures
0
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
23
Page 32 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
511a
SC101805 Appeal Document Number 26 Page 34
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
Dent County
U.S. Representative District 8
1. Number of Signatures found valid as "R"
0
2. Number of signatures found valid as "RDA"
0
3. Total Number of Valid Signatures (add 1 and 2)
0
4. Number of Signatures found invalid as "NR"
0
5. Number of Signatures found invalid as "WA"
0
6. Number of Signatures found invalid as "WS"
0
7. Total Number of Invalid Signatures (add 4, 5 and 6)
0
8. Total number of duplicate signatures
0
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
0
Page 33 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
512a
SC101805 Appeal Document Number 26 Page 35
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
Douglas County
U.S. Representative District 8
1. Number of Signatures found valid as "R"
102
2. Number of signatures found valid as "RDA"
8
3. Total Number of Valid Signatures (add 1 and 2)
110
4. Number of Signatures found invalid as "NR"
10
5. Number of Signatures found invalid as "WA"
7
6. Number of Signatures found invalid as "WS"
7
7. Total Number of Invalid Signatures (add 4, 5 and 6)
24
8. Total number of duplicate signatures
2
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
136
Page 34 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
513a
SC101805 Appeal Document Number 26 Page 36
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
Dunklin County
U.S. Representative District 8
1. Number of Signatures found valid as "R"
0
2. Number of signatures found valid as "RDA"
0
3. Total Number of Valid Signatures (add 1 and 2)
0
4. Number of Signatures found invalid as "NR"
0
5. Number of Signatures found invalid as "WA"
0
6. Number of Signatures found invalid as "WS"
0
7. Total Number of Invalid Signatures (add 4, 5 and 6)
0
8. Total number of duplicate signatures
0
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
0
Page 35 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
514a
SC101805 Appeal Document Number 26 Page 37
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
Franklin County
U.S. Representative District 2
1. Number of Signatures found valid as "R"
899
2. Number of signatures found valid as "RDA"
22
3. Total Number of Valid Signatures (add 1 and 2)
921
4. Number of Signatures found invalid as "NR"
158
5. Number of Signatures found invalid as "WA"
13
6. Number of Signatures found invalid as "WS"
9
7. Total Number of Invalid Signatures (add 4, 5 and 6)
180
8. Total number of duplicate signatures
13
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
1114
Page 36 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
515a
SC101805 Appeal Document Number 26 Page 38
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
Gasconade County
U.S. Representative District 3
1. Number of Signatures found valid as "R"
108
2. Number of signatures found valid as "RDA"
2
3. Total Number of Valid Signatures (add 1 and 2)
110
4. Number of Signatures found invalid as "NR"
14
5. Number of Signatures found invalid as "WA"
0
6. Number of Signatures found invalid as "WS"
0
7. Total Number of Invalid Signatures (add 4, 5 and 6)
14
8. Total number of duplicate signatures
3
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
127
Page 37 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
516a
SC101805 Appeal Document Number 26 Page 39
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
Gentry County
U.S. Representative District 6
1. Number of Signatures found valid as "R"
51
2. Number of signatures found valid as "RDA"
0
3. Total Number of Valid Signatures (add 1 and 2)
51
4. Number of Signatures found invalid as "NR"
1
5. Number of Signatures found invalid as "WA"
0
6. Number of Signatures found invalid as "WS"
5
7. Total Number of Invalid Signatures (add 4, 5 and 6)
6
8. Total number of duplicate signatures
0
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
57
Page 38 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
517a
SC101805 Appeal Document Number 26 Page 40
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
Greene County
U.S. Representative District 7
1. Number of Signatures found valid as "R"
11267
2. Number of signatures found valid as "RDA"
657
3. Total Number of Valid Signatures (add 1 and 2)
11924
4. Number of Signatures found invalid as "NR"
1802
5. Number of Signatures found invalid as "WA"
148
6. Number of Signatures found invalid as "WS"
524
7. Total Number of Invalid Signatures (add 4, 5 and 6)
2474
8. Total number of duplicate signatures
380
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
14778
Page 39 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
518a
SC101805 Appeal Document Number 26 Page 41
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
Grundy County
U.S. Representative District 6
1. Number of Signatures found valid as "R"
33
2. Number of signatures found valid as "RDA"
0
3. Total Number of Valid Signatures (add 1 and 2)
33
4. Number of Signatures found invalid as "NR"
0
5. Number of Signatures found invalid as "WA"
0
6. Number of Signatures found invalid as "WS"
0
7. Total Number of Invalid Signatures (add 4, 5 and 6)
0
8. Total number of duplicate signatures
0
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
33
Page 40 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
519a
SC101805 Appeal Document Number 26 Page 42
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
Harrison County
U.S. Representative District 6
1. Number of Signatures found valid as "R"
9
2. Number of signatures found valid as "RDA"
0
3. Total Number of Valid Signatures (add 1 and 2)
9
4. Number of Signatures found invalid as "NR"
0
5. Number of Signatures found invalid as "WA"
1
6. Number of Signatures found invalid as "WS"
2
7. Total Number of Invalid Signatures (add 4, 5 and 6)
3
8. Total number of duplicate signatures
1
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
13
Page 41 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
520a
SC101805 Appeal Document Number 26 Page 43
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
Henry County
U.S. Representative District 4
1. Number of Signatures found valid as "R"
258
2. Number of signatures found valid as "RDA"
4
3. Total Number of Valid Signatures (add 1 and 2)
262
4. Number of Signatures found invalid as "NR"
26
5. Number of Signatures found invalid as "WA"
0
6. Number of Signatures found invalid as "WS"
10
7. Total Number of Invalid Signatures (add 4, 5 and 6)
36
8. Total number of duplicate signatures
8
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
306
Page 42 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
521a
SC101805 Appeal Document Number 26 Page 44
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
Hickory County
U.S. Representative District 4
1. Number of Signatures found valid as "R"
100
2. Number of signatures found valid as "RDA"
0
3. Total Number of Valid Signatures (add 1 and 2)
100
4. Number of Signatures found invalid as "NR"
11
5. Number of Signatures found invalid as "WA"
11
6. Number of Signatures found invalid as "WS"
7
7. Total Number of Invalid Signatures (add 4, 5 and 6)
29
8. Total number of duplicate signatures
1
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
130
Page 43 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
522a
SC101805 Appeal Document Number 26 Page 45
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
Holt County
U.S. Representative District 6
1. Number of Signatures found valid as "R"
61
2. Number of signatures found valid as "RDA"
0
3. Total Number of Valid Signatures (add 1 and 2)
61
4. Number of Signatures found invalid as "NR"
0
5. Number of Signatures found invalid as "WA"
0
6. Number of Signatures found invalid as "WS"
0
7. Total Number of Invalid Signatures (add 4, 5 and 6)
0
8. Total number of duplicate signatures
4
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
65
Page 44 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
523a
SC101805 Appeal Document Number 26 Page 46
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
Howard County
U.S. Representative District 4
1. Number of Signatures found valid as "R"
348
2. Number of signatures found valid as "RDA"
12
3. Total Number of Valid Signatures (add 1 and 2)
360
4. Number of Signatures found invalid as "NR"
67
5. Number of Signatures found invalid as "WA"
1
6. Number of Signatures found invalid as "WS"
21
7. Total Number of Invalid Signatures (add 4, 5 and 6)
89
8. Total number of duplicate signatures
11
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
460
Page 45 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
524a
SC101805 Appeal Document Number 26 Page 47
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
Howell County
U.S. Representative District 8
1. Number of Signatures found valid as "R"
0
2. Number of signatures found valid as "RDA"
0
3. Total Number of Valid Signatures (add 1 and 2)
0
4. Number of Signatures found invalid as "NR"
0
5. Number of Signatures found invalid as "WA"
0
6. Number of Signatures found invalid as "WS"
0
7. Total Number of Invalid Signatures (add 4, 5 and 6)
0
8. Total number of duplicate signatures
0
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
0
Page 46 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
525a
SC101805 Appeal Document Number 26 Page 48
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
Iron County
U.S. Representative District 8
1. Number of Signatures found valid as "R"
0
2. Number of signatures found valid as "RDA"
0
3. Total Number of Valid Signatures (add 1 and 2)
0
4. Number of Signatures found invalid as "NR"
0
5. Number of Signatures found invalid as "WA"
0
6. Number of Signatures found invalid as "WS"
0
7. Total Number of Invalid Signatures (add 4, 5 and 6)
0
8. Total number of duplicate signatures
0
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
0
Page 47 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
526a
SC101805 Appeal Document Number 26 Page 49
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
Jackson County
U.S. Representative District 4
1. Number of Signatures found valid as "R"
5407
2. Number of signatures found valid as "RDA"
153
3. Total Number of Valid Signatures (add 1 and 2)
5560
4. Number of Signatures found invalid as "NR"
4197
5. Number of Signatures found invalid as "WA"
43
6. Number of Signatures found invalid as "WS"
181
7. Total Number of Invalid Signatures (add 4, 5 and 6)
4421
8. Total number of duplicate signatures
174
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
10155
U.S. Representative District 5
1. Number of Signatures found valid as "R"
20589
2. Number of signatures found valid as "RDA"
1410
3. Total Number of Valid Signatures (add 1 and 2)
21999
4. Number of Signatures found invalid as "NR"
0
5. Number of Signatures found invalid as "WA"
0
6. Number of Signatures found invalid as "WS"
623
7. Total Number of Invalid Signatures (add 4, 5 and 6)
623
8. Total number of duplicate signatures
530
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
23152
U.S. Representative District 6
1. Number of Signatures found valid as "R"
222
2. Number of signatures found valid as "RDA"
23
3. Total Number of Valid Signatures (add 1 and 2)
245
4. Number of Signatures found invalid as "NR"
0
5. Number of Signatures found invalid as "WA"
0
6. Number of Signatures found invalid as "WS"
6
7. Total Number of Invalid Signatures (add 4, 5 and 6)
6
Page 48 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
527a
SC101805 Appeal Document Number 26 Page 50
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
8. Total number of duplicate signatures
5
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
256
Page 49 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
528a
SC101805 Appeal Document Number 26 Page 51
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
Jasper County
U.S. Representative District 7
1. Number of Signatures found valid as "R"
4496
2. Number of signatures found valid as "RDA"
576
3. Total Number of Valid Signatures (add 1 and 2)
5072
4. Number of Signatures found invalid as "NR"
1282
5. Number of Signatures found invalid as "WA"
19
6. Number of Signatures found invalid as "WS"
62
7. Total Number of Invalid Signatures (add 4, 5 and 6)
1363
8. Total number of duplicate signatures
196
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
6631
Page 50 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
529a
SC101805 Appeal Document Number 26 Page 52
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
Jefferson County
U.S. Representative District 3
1. Number of Signatures found valid as "R"
1338
2. Number of signatures found valid as "RDA"
41
3. Total Number of Valid Signatures (add 1 and 2)
1379
4. Number of Signatures found invalid as "NR"
341
5. Number of Signatures found invalid as "WA"
37
6. Number of Signatures found invalid as "WS"
15
7. Total Number of Invalid Signatures (add 4, 5 and 6)
393
8. Total number of duplicate signatures
25
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
1797
U.S. Representative District 8
1. Number of Signatures found valid as "R"
2304
2. Number of signatures found valid as "RDA"
99
3. Total Number of Valid Signatures (add 1 and 2)
2403
4. Number of Signatures found invalid as "NR"
0
5. Number of Signatures found invalid as "WA"
0
6. Number of Signatures found invalid as "WS"
42
7. Total Number of Invalid Signatures (add 4, 5 and 6)
42
8. Total number of duplicate signatures
31
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
2476
Page 51 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
530a
SC101805 Appeal Document Number 26 Page 53
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
Johnson County
U.S. Representative District 4
1. Number of Signatures found valid as "R"
805
2. Number of signatures found valid as "RDA"
47
3. Total Number of Valid Signatures (add 1 and 2)
852
4. Number of Signatures found invalid as "NR"
322
5. Number of Signatures found invalid as "WA"
5
6. Number of Signatures found invalid as "WS"
95
7. Total Number of Invalid Signatures (add 4, 5 and 6)
422
8. Total number of duplicate signatures
14
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
1288
Page 52 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
531a
SC101805 Appeal Document Number 26 Page 54
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
Kansas City County
U.S. Representative District 5
1. Number of Signatures found valid as "R"
0
2. Number of signatures found valid as "RDA"
0
3. Total Number of Valid Signatures (add 1 and 2)
0
4. Number of Signatures found invalid as "NR"
0
5. Number of Signatures found invalid as "WA"
0
6. Number of Signatures found invalid as "WS"
0
7. Total Number of Invalid Signatures (add 4, 5 and 6)
0
8. Total number of duplicate signatures
0
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
0
Page 53 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
532a
SC101805 Appeal Document Number 26 Page 55
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
Knox County
U.S. Representative District 6
1. Number of Signatures found valid as "R"
3
2. Number of signatures found valid as "RDA"
0
3. Total Number of Valid Signatures (add 1 and 2)
3
4. Number of Signatures found invalid as "NR"
0
5. Number of Signatures found invalid as "WA"
0
6. Number of Signatures found invalid as "WS"
0
7. Total Number of Invalid Signatures (add 4, 5 and 6)
0
8. Total number of duplicate signatures
0
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
3
Page 54 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
533a
SC101805 Appeal Document Number 26 Page 56
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
Laclede County
U.S. Representative District 4
1. Number of Signatures found valid as "R"
526
2. Number of signatures found valid as "RDA"
28
3. Total Number of Valid Signatures (add 1 and 2)
554
4. Number of Signatures found invalid as "NR"
55
5. Number of Signatures found invalid as "WA"
5
6. Number of Signatures found invalid as "WS"
8
7. Total Number of Invalid Signatures (add 4, 5 and 6)
68
8. Total number of duplicate signatures
11
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
633
Page 55 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
534a
SC101805 Appeal Document Number 26 Page 57
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
Lafayette County
U.S. Representative District 4
1. Number of Signatures found valid as "R"
460
2. Number of signatures found valid as "RDA"
11
3. Total Number of Valid Signatures (add 1 and 2)
471
4. Number of Signatures found invalid as "NR"
62
5. Number of Signatures found invalid as "WA"
1
6. Number of Signatures found invalid as "WS"
0
7. Total Number of Invalid Signatures (add 4, 5 and 6)
63
8. Total number of duplicate signatures
6
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
540
Page 56 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
535a
SC101805 Appeal Document Number 26 Page 58
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
Lawrence County
U.S. Representative District 7
1. Number of Signatures found valid as "R"
507
2. Number of signatures found valid as "RDA"
26
3. Total Number of Valid Signatures (add 1 and 2)
533
4. Number of Signatures found invalid as "NR"
83
5. Number of Signatures found invalid as "WA"
20
6. Number of Signatures found invalid as "WS"
37
7. Total Number of Invalid Signatures (add 4, 5 and 6)
140
8. Total number of duplicate signatures
4
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
677
Page 57 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
536a
SC101805 Appeal Document Number 26 Page 59
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
Lewis County
U.S. Representative District 6
1. Number of Signatures found valid as "R"
39
2. Number of signatures found valid as "RDA"
0
3. Total Number of Valid Signatures (add 1 and 2)
39
4. Number of Signatures found invalid as "NR"
1
5. Number of Signatures found invalid as "WA"
0
6. Number of Signatures found invalid as "WS"
0
7. Total Number of Invalid Signatures (add 4, 5 and 6)
1
8. Total number of duplicate signatures
1
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
41
Page 58 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
537a
SC101805 Appeal Document Number 26 Page 60
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
Lincoln County
U.S. Representative District 6
1. Number of Signatures found valid as "R"
812
2. Number of signatures found valid as "RDA"
17
3. Total Number of Valid Signatures (add 1 and 2)
829
4. Number of Signatures found invalid as "NR"
114
5. Number of Signatures found invalid as "WA"
24
6. Number of Signatures found invalid as "WS"
21
7. Total Number of Invalid Signatures (add 4, 5 and 6)
159
8. Total number of duplicate signatures
14
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
1002
Page 59 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
538a
SC101805 Appeal Document Number 26 Page 61
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
Linn County
U.S. Representative District 6
1. Number of Signatures found valid as "R"
56
2. Number of signatures found valid as "RDA"
1
3. Total Number of Valid Signatures (add 1 and 2)
57
4. Number of Signatures found invalid as "NR"
10
5. Number of Signatures found invalid as "WA"
1
6. Number of Signatures found invalid as "WS"
2
7. Total Number of Invalid Signatures (add 4, 5 and 6)
13
8. Total number of duplicate signatures
0
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
70
Page 60 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
539a
SC101805 Appeal Document Number 26 Page 62
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
Livingston County
U.S. Representative District 6
1. Number of Signatures found valid as "R"
80
2. Number of signatures found valid as "RDA"
0
3. Total Number of Valid Signatures (add 1 and 2)
80
4. Number of Signatures found invalid as "NR"
6
5. Number of Signatures found invalid as "WA"
1
6. Number of Signatures found invalid as "WS"
2
7. Total Number of Invalid Signatures (add 4, 5 and 6)
9
8. Total number of duplicate signatures
4
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
93
Page 61 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
540a
SC101805 Appeal Document Number 26 Page 63
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
Macon County
U.S. Representative District 6
1. Number of Signatures found valid as "R"
62
2. Number of signatures found valid as "RDA"
4
3. Total Number of Valid Signatures (add 1 and 2)
66
4. Number of Signatures found invalid as "NR"
6
5. Number of Signatures found invalid as "WA"
0
6. Number of Signatures found invalid as "WS"
3
7. Total Number of Invalid Signatures (add 4, 5 and 6)
9
8. Total number of duplicate signatures
1
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
76
Page 62 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
541a
SC101805 Appeal Document Number 26 Page 64
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
Madison County
U.S. Representative District 8
1. Number of Signatures found valid as "R"
2
2. Number of signatures found valid as "RDA"
0
3. Total Number of Valid Signatures (add 1 and 2)
2
4. Number of Signatures found invalid as "NR"
0
5. Number of Signatures found invalid as "WA"
0
6. Number of Signatures found invalid as "WS"
0
7. Total Number of Invalid Signatures (add 4, 5 and 6)
0
8. Total number of duplicate signatures
0
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
2
Page 63 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
542a
SC101805 Appeal Document Number 26 Page 65
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
Maries County
U.S. Representative District 3
1. Number of Signatures found valid as "R"
93
2. Number of signatures found valid as "RDA"
3
3. Total Number of Valid Signatures (add 1 and 2)
96
4. Number of Signatures found invalid as "NR"
9
5. Number of Signatures found invalid as "WA"
3
6. Number of Signatures found invalid as "WS"
4
7. Total Number of Invalid Signatures (add 4, 5 and 6)
16
8. Total number of duplicate signatures
3
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
115
Page 64 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
543a
SC101805 Appeal Document Number 26 Page 66
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
Marion County
U.S. Representative District 6
1. Number of Signatures found valid as "R"
135
2. Number of signatures found valid as "RDA"
3
3. Total Number of Valid Signatures (add 1 and 2)
138
4. Number of Signatures found invalid as "NR"
8
5. Number of Signatures found invalid as "WA"
3
6. Number of Signatures found invalid as "WS"
0
7. Total Number of Invalid Signatures (add 4, 5 and 6)
11
8. Total number of duplicate signatures
0
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
149
Page 65 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
544a
SC101805 Appeal Document Number 26 Page 67
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
McDonald County
U.S. Representative District 7
1. Number of Signatures found valid as "R"
211
2. Number of signatures found valid as "RDA"
11
3. Total Number of Valid Signatures (add 1 and 2)
222
4. Number of Signatures found invalid as "NR"
31
5. Number of Signatures found invalid as "WA"
4
6. Number of Signatures found invalid as "WS"
7
7. Total Number of Invalid Signatures (add 4, 5 and 6)
42
8. Total number of duplicate signatures
4
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
268
Page 66 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
545a
SC101805 Appeal Document Number 26 Page 68
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
Mercer County
U.S. Representative District 6
1. Number of Signatures found valid as "R"
3
2. Number of signatures found valid as "RDA"
0
3. Total Number of Valid Signatures (add 1 and 2)
3
4. Number of Signatures found invalid as "NR"
0
5. Number of Signatures found invalid as "WA"
0
6. Number of Signatures found invalid as "WS"
0
7. Total Number of Invalid Signatures (add 4, 5 and 6)
0
8. Total number of duplicate signatures
0
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
3
Page 67 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
546a
SC101805 Appeal Document Number 26 Page 69
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
Miller County
U.S. Representative District 3
1. Number of Signatures found valid as "R"
184
2. Number of signatures found valid as "RDA"
5
3. Total Number of Valid Signatures (add 1 and 2)
189
4. Number of Signatures found invalid as "NR"
32
5. Number of Signatures found invalid as "WA"
0
6. Number of Signatures found invalid as "WS"
1
7. Total Number of Invalid Signatures (add 4, 5 and 6)
33
8. Total number of duplicate signatures
2
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
224
Page 68 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
547a
SC101805 Appeal Document Number 26 Page 70
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
Mississippi County
U.S. Representative District 8
1. Number of Signatures found valid as "R"
0
2. Number of signatures found valid as "RDA"
0
3. Total Number of Valid Signatures (add 1 and 2)
0
4. Number of Signatures found invalid as "NR"
0
5. Number of Signatures found invalid as "WA"
0
6. Number of Signatures found invalid as "WS"
0
7. Total Number of Invalid Signatures (add 4, 5 and 6)
0
8. Total number of duplicate signatures
0
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
0
Page 69 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
548a
SC101805 Appeal Document Number 26 Page 71
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
Moniteau County
U.S. Representative District 3
1. Number of Signatures found valid as "R"
149
2. Number of signatures found valid as "RDA"
6
3. Total Number of Valid Signatures (add 1 and 2)
155
4. Number of Signatures found invalid as "NR"
17
5. Number of Signatures found invalid as "WA"
9
6. Number of Signatures found invalid as "WS"
0
7. Total Number of Invalid Signatures (add 4, 5 and 6)
26
8. Total number of duplicate signatures
1
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
182
Page 70 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
549a
SC101805 Appeal Document Number 26 Page 72
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
Monroe County
U.S. Representative District 6
1. Number of Signatures found valid as "R"
38
2. Number of signatures found valid as "RDA"
0
3. Total Number of Valid Signatures (add 1 and 2)
38
4. Number of Signatures found invalid as "NR"
12
5. Number of Signatures found invalid as "WA"
1
6. Number of Signatures found invalid as "WS"
0
7. Total Number of Invalid Signatures (add 4, 5 and 6)
13
8. Total number of duplicate signatures
1
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
52
Page 71 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
550a
SC101805 Appeal Document Number 26 Page 73
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
Montgomery County
U.S. Representative District 3
1. Number of Signatures found valid as "R"
100
2. Number of signatures found valid as "RDA"
1
3. Total Number of Valid Signatures (add 1 and 2)
101
4. Number of Signatures found invalid as "NR"
15
5. Number of Signatures found invalid as "WA"
2
6. Number of Signatures found invalid as "WS"
16
7. Total Number of Invalid Signatures (add 4, 5 and 6)
33
8. Total number of duplicate signatures
0
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
134
Page 72 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
551a
SC101805 Appeal Document Number 26 Page 74
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
Morgan County
U.S. Representative District 4
1. Number of Signatures found valid as "R"
129
2. Number of signatures found valid as "RDA"
3
3. Total Number of Valid Signatures (add 1 and 2)
132
4. Number of Signatures found invalid as "NR"
10
5. Number of Signatures found invalid as "WA"
11
6. Number of Signatures found invalid as "WS"
5
7. Total Number of Invalid Signatures (add 4, 5 and 6)
26
8. Total number of duplicate signatures
3
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
161
Page 73 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
552a
SC101805 Appeal Document Number 26 Page 75
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
New Madrid County
U.S. Representative District 8
1. Number of Signatures found valid as "R"
0
2. Number of signatures found valid as "RDA"
0
3. Total Number of Valid Signatures (add 1 and 2)
0
4. Number of Signatures found invalid as "NR"
0
5. Number of Signatures found invalid as "WA"
0
6. Number of Signatures found invalid as "WS"
0
7. Total Number of Invalid Signatures (add 4, 5 and 6)
0
8. Total number of duplicate signatures
0
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
0
Page 74 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
553a
SC101805 Appeal Document Number 26 Page 76
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
Newton County
U.S. Representative District 7
1. Number of Signatures found valid as "R"
1609
2. Number of signatures found valid as "RDA"
49
3. Total Number of Valid Signatures (add 1 and 2)
1658
4. Number of Signatures found invalid as "NR"
463
5. Number of Signatures found invalid as "WA"
11
6. Number of Signatures found invalid as "WS"
5
7. Total Number of Invalid Signatures (add 4, 5 and 6)
479
8. Total number of duplicate signatures
44
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
2181
Page 75 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
554a
SC101805 Appeal Document Number 26 Page 77
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
Nodaway County
U.S. Representative District 6
1. Number of Signatures found valid as "R"
149
2. Number of signatures found valid as "RDA"
2
3. Total Number of Valid Signatures (add 1 and 2)
151
4. Number of Signatures found invalid as "NR"
11
5. Number of Signatures found invalid as "WA"
0
6. Number of Signatures found invalid as "WS"
3
7. Total Number of Invalid Signatures (add 4, 5 and 6)
14
8. Total number of duplicate signatures
3
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
168
Page 76 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
555a
SC101805 Appeal Document Number 26 Page 78
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
Oregon County
U.S. Representative District 8
1. Number of Signatures found valid as "R"
12
2. Number of signatures found valid as "RDA"
2
3. Total Number of Valid Signatures (add 1 and 2)
14
4. Number of Signatures found invalid as "NR"
3
5. Number of Signatures found invalid as "WA"
0
6. Number of Signatures found invalid as "WS"
0
7. Total Number of Invalid Signatures (add 4, 5 and 6)
3
8. Total number of duplicate signatures
0
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
17
Page 77 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
556a
SC101805 Appeal Document Number 26 Page 79
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
Osage County
U.S. Representative District 3
1. Number of Signatures found valid as "R"
106
2. Number of signatures found valid as "RDA"
4
3. Total Number of Valid Signatures (add 1 and 2)
110
4. Number of Signatures found invalid as "NR"
14
5. Number of Signatures found invalid as "WA"
0
6. Number of Signatures found invalid as "WS"
0
7. Total Number of Invalid Signatures (add 4, 5 and 6)
14
8. Total number of duplicate signatures
0
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
124
Page 78 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
557a
SC101805 Appeal Document Number 26 Page 80
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
Ozark County
U.S. Representative District 8
1. Number of Signatures found valid as "R"
0
2. Number of signatures found valid as "RDA"
0
3. Total Number of Valid Signatures (add 1 and 2)
0
4. Number of Signatures found invalid as "NR"
0
5. Number of Signatures found invalid as "WA"
0
6. Number of Signatures found invalid as "WS"
0
7. Total Number of Invalid Signatures (add 4, 5 and 6)
0
8. Total number of duplicate signatures
0
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
0
Page 79 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
558a
SC101805 Appeal Document Number 26 Page 81
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
Pemiscot County
U.S. Representative District 8
1. Number of Signatures found valid as "R"
0
2. Number of signatures found valid as "RDA"
0
3. Total Number of Valid Signatures (add 1 and 2)
0
4. Number of Signatures found invalid as "NR"
0
5. Number of Signatures found invalid as "WA"
0
6. Number of Signatures found invalid as "WS"
0
7. Total Number of Invalid Signatures (add 4, 5 and 6)
0
8. Total number of duplicate signatures
0
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
0
Page 80 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
559a
SC101805 Appeal Document Number 26 Page 82
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
Perry County
U.S. Representative District 8
1. Number of Signatures found valid as "R"
0
2. Number of signatures found valid as "RDA"
0
3. Total Number of Valid Signatures (add 1 and 2)
0
4. Number of Signatures found invalid as "NR"
0
5. Number of Signatures found invalid as "WA"
0
6. Number of Signatures found invalid as "WS"
0
7. Total Number of Invalid Signatures (add 4, 5 and 6)
0
8. Total number of duplicate signatures
0
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
0
Page 81 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
560a
SC101805 Appeal Document Number 26 Page 83
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
Pettis County
U.S. Representative District 4
1. Number of Signatures found valid as "R"
1099
2. Number of signatures found valid as "RDA"
20
3. Total Number of Valid Signatures (add 1 and 2)
1119
4. Number of Signatures found invalid as "NR"
255
5. Number of Signatures found invalid as "WA"
2
6. Number of Signatures found invalid as "WS"
55
7. Total Number of Invalid Signatures (add 4, 5 and 6)
312
8. Total number of duplicate signatures
21
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
1452
Page 82 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
561a
SC101805 Appeal Document Number 26 Page 84
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
Phelps County
U.S. Representative District 8
1. Number of Signatures found valid as "R"
0
2. Number of signatures found valid as "RDA"
0
3. Total Number of Valid Signatures (add 1 and 2)
0
4. Number of Signatures found invalid as "NR"
0
5. Number of Signatures found invalid as "WA"
0
6. Number of Signatures found invalid as "WS"
0
7. Total Number of Invalid Signatures (add 4, 5 and 6)
0
8. Total number of duplicate signatures
0
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
0
Page 83 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
562a
SC101805 Appeal Document Number 26 Page 85
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
Pike County
U.S. Representative District 6
1. Number of Signatures found valid as "R"
70
2. Number of signatures found valid as "RDA"
0
3. Total Number of Valid Signatures (add 1 and 2)
70
4. Number of Signatures found invalid as "NR"
17
5. Number of Signatures found invalid as "WA"
0
6. Number of Signatures found invalid as "WS"
0
7. Total Number of Invalid Signatures (add 4, 5 and 6)
17
8. Total number of duplicate signatures
1
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
88
Page 84 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
563a
SC101805 Appeal Document Number 26 Page 86
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
Platte County
U.S. Representative District 6
1. Number of Signatures found valid as "R"
1504
2. Number of signatures found valid as "RDA"
18
3. Total Number of Valid Signatures (add 1 and 2)
1522
4. Number of Signatures found invalid as "NR"
62
5. Number of Signatures found invalid as "WA"
26
6. Number of Signatures found invalid as "WS"
9
7. Total Number of Invalid Signatures (add 4, 5 and 6)
97
8. Total number of duplicate signatures
23
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
1642
Page 85 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
564a
SC101805 Appeal Document Number 26 Page 87
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
Polk County
U.S. Representative District 4
1. Number of Signatures found valid as "R"
549
2. Number of signatures found valid as "RDA"
35
3. Total Number of Valid Signatures (add 1 and 2)
584
4. Number of Signatures found invalid as "NR"
92
5. Number of Signatures found invalid as "WA"
4
6. Number of Signatures found invalid as "WS"
5
7. Total Number of Invalid Signatures (add 4, 5 and 6)
101
8. Total number of duplicate signatures
5
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
690
Page 86 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
565a
SC101805 Appeal Document Number 26 Page 88
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
Pulaski County
U.S. Representative District 4
1. Number of Signatures found valid as "R"
725
2. Number of signatures found valid as "RDA"
49
3. Total Number of Valid Signatures (add 1 and 2)
774
4. Number of Signatures found invalid as "NR"
301
5. Number of Signatures found invalid as "WA"
7
6. Number of Signatures found invalid as "WS"
4
7. Total Number of Invalid Signatures (add 4, 5 and 6)
312
8. Total number of duplicate signatures
17
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
1103
Page 87 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
566a
SC101805 Appeal Document Number 26 Page 89
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
Putnam County
U.S. Representative District 6
1. Number of Signatures found valid as "R"
9
2. Number of signatures found valid as "RDA"
0
3. Total Number of Valid Signatures (add 1 and 2)
9
4. Number of Signatures found invalid as "NR"
1
5. Number of Signatures found invalid as "WA"
0
6. Number of Signatures found invalid as "WS"
1
7. Total Number of Invalid Signatures (add 4, 5 and 6)
2
8. Total number of duplicate signatures
1
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
12
Page 88 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
567a
SC101805 Appeal Document Number 26 Page 90
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
Ralls County
U.S. Representative District 6
1. Number of Signatures found valid as "R"
46
2. Number of signatures found valid as "RDA"
2
3. Total Number of Valid Signatures (add 1 and 2)
48
4. Number of Signatures found invalid as "NR"
3
5. Number of Signatures found invalid as "WA"
3
6. Number of Signatures found invalid as "WS"
2
7. Total Number of Invalid Signatures (add 4, 5 and 6)
8
8. Total number of duplicate signatures
1
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
57
Page 89 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
568a
SC101805 Appeal Document Number 26 Page 91
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
Randolph County
U.S. Representative District 6
1. Number of Signatures found valid as "R"
419
2. Number of signatures found valid as "RDA"
17
3. Total Number of Valid Signatures (add 1 and 2)
436
4. Number of Signatures found invalid as "NR"
112
5. Number of Signatures found invalid as "WA"
1
6. Number of Signatures found invalid as "WS"
32
7. Total Number of Invalid Signatures (add 4, 5 and 6)
145
8. Total number of duplicate signatures
6
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
587
Page 90 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
569a
SC101805 Appeal Document Number 26 Page 92
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
Ray County
U.S. Representative District 6
1. Number of Signatures found valid as "R"
126
2. Number of signatures found valid as "RDA"
2
3. Total Number of Valid Signatures (add 1 and 2)
128
4. Number of Signatures found invalid as "NR"
7
5. Number of Signatures found invalid as "WA"
3
6. Number of Signatures found invalid as "WS"
14
7. Total Number of Invalid Signatures (add 4, 5 and 6)
24
8. Total number of duplicate signatures
2
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
154
Page 91 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
570a
SC101805 Appeal Document Number 26 Page 93
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
Reynolds County
U.S. Representative District 8
1. Number of Signatures found valid as "R"
5
2. Number of signatures found valid as "RDA"
0
3. Total Number of Valid Signatures (add 1 and 2)
5
4. Number of Signatures found invalid as "NR"
0
5. Number of Signatures found invalid as "WA"
0
6. Number of Signatures found invalid as "WS"
0
7. Total Number of Invalid Signatures (add 4, 5 and 6)
0
8. Total number of duplicate signatures
0
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
5
Page 92 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
571a
SC101805 Appeal Document Number 26 Page 94
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
Ripley County
U.S. Representative District 8
1. Number of Signatures found valid as "R"
11
2. Number of signatures found valid as "RDA"
1
3. Total Number of Valid Signatures (add 1 and 2)
12
4. Number of Signatures found invalid as "NR"
0
5. Number of Signatures found invalid as "WA"
1
6. Number of Signatures found invalid as "WS"
0
7. Total Number of Invalid Signatures (add 4, 5 and 6)
1
8. Total number of duplicate signatures
0
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
13
Page 93 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
572a
SC101805 Appeal Document Number 26 Page 95
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
Saline County
U.S. Representative District 4
1. Number of Signatures found valid as "R"
408
2. Number of signatures found valid as "RDA"
12
3. Total Number of Valid Signatures (add 1 and 2)
420
4. Number of Signatures found invalid as "NR"
33
5. Number of Signatures found invalid as "WA"
5
6. Number of Signatures found invalid as "WS"
7
7. Total Number of Invalid Signatures (add 4, 5 and 6)
45
8. Total number of duplicate signatures
9
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
474
Page 94 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
573a
SC101805 Appeal Document Number 26 Page 96
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
Schuyler County
U.S. Representative District 6
1. Number of Signatures found valid as "R"
2
2. Number of signatures found valid as "RDA"
1
3. Total Number of Valid Signatures (add 1 and 2)
3
4. Number of Signatures found invalid as "NR"
0
5. Number of Signatures found invalid as "WA"
0
6. Number of Signatures found invalid as "WS"
0
7. Total Number of Invalid Signatures (add 4, 5 and 6)
0
8. Total number of duplicate signatures
0
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
3
Page 95 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
574a
SC101805 Appeal Document Number 26 Page 97
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
Scotland County
U.S. Representative District 6
1. Number of Signatures found valid as "R"
5
2. Number of signatures found valid as "RDA"
0
3. Total Number of Valid Signatures (add 1 and 2)
5
4. Number of Signatures found invalid as "NR"
5
5. Number of Signatures found invalid as "WA"
0
6. Number of Signatures found invalid as "WS"
1
7. Total Number of Invalid Signatures (add 4, 5 and 6)
6
8. Total number of duplicate signatures
0
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
11
Page 96 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
575a
SC101805 Appeal Document Number 26 Page 98
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
Scott County
U.S. Representative District 8
1. Number of Signatures found valid as "R"
1
2. Number of signatures found valid as "RDA"
0
3. Total Number of Valid Signatures (add 1 and 2)
1
4. Number of Signatures found invalid as "NR"
0
5. Number of Signatures found invalid as "WA"
0
6. Number of Signatures found invalid as "WS"
0
7. Total Number of Invalid Signatures (add 4, 5 and 6)
0
8. Total number of duplicate signatures
0
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
1
Page 97 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
576a
SC101805 Appeal Document Number 26 Page 99
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
Shannon County
U.S. Representative District 8
1. Number of Signatures found valid as "R"
0
2. Number of signatures found valid as "RDA"
0
3. Total Number of Valid Signatures (add 1 and 2)
0
4. Number of Signatures found invalid as "NR"
0
5. Number of Signatures found invalid as "WA"
0
6. Number of Signatures found invalid as "WS"
0
7. Total Number of Invalid Signatures (add 4, 5 and 6)
0
8. Total number of duplicate signatures
0
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
0
Page 98 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
577a
SC101805 Appeal Document Number 26 Page 100
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
Shelby County
U.S. Representative District 6
1. Number of Signatures found valid as "R"
9
2. Number of signatures found valid as "RDA"
0
3. Total Number of Valid Signatures (add 1 and 2)
9
4. Number of Signatures found invalid as "NR"
3
5. Number of Signatures found invalid as "WA"
0
6. Number of Signatures found invalid as "WS"
0
7. Total Number of Invalid Signatures (add 4, 5 and 6)
3
8. Total number of duplicate signatures
0
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
12
Page 99 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
578a
SC101805 Appeal Document Number 26 Page 101
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
St. Charles County
U.S. Representative District 2
1. Number of Signatures found valid as "R"
3693
2. Number of signatures found valid as "RDA"
202
3. Total Number of Valid Signatures (add 1 and 2)
3895
4. Number of Signatures found invalid as "NR"
1459
5. Number of Signatures found invalid as "WA"
335
6. Number of Signatures found invalid as "WS"
28
7. Total Number of Invalid Signatures (add 4, 5 and 6)
1822
8. Total number of duplicate signatures
91
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
5808
U.S. Representative District 3
1. Number of Signatures found valid as "R"
12918
2. Number of signatures found valid as "RDA"
691
3. Total Number of Valid Signatures (add 1 and 2)
13609
4. Number of Signatures found invalid as "NR"
0
5. Number of Signatures found invalid as "WA"
0
6. Number of Signatures found invalid as "WS"
120
7. Total Number of Invalid Signatures (add 4, 5 and 6)
120
8. Total number of duplicate signatures
402
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
14131
Page 100 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
579a
SC101805 Appeal Document Number 26 Page 102
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
St. Clair County
U.S. Representative District 4
1. Number of Signatures found valid as "R"
52
2. Number of signatures found valid as "RDA"
4
3. Total Number of Valid Signatures (add 1 and 2)
56
4. Number of Signatures found invalid as "NR"
6
5. Number of Signatures found invalid as "WA"
1
6. Number of Signatures found invalid as "WS"
2
7. Total Number of Invalid Signatures (add 4, 5 and 6)
9
8. Total number of duplicate signatures
2
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
67
Page 101 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
580a
SC101805 Appeal Document Number 26 Page 103
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
St. Francois County
U.S. Representative District 8
1. Number of Signatures found valid as "R"
0
2. Number of signatures found valid as "RDA"
0
3. Total Number of Valid Signatures (add 1 and 2)
0
4. Number of Signatures found invalid as "NR"
0
5. Number of Signatures found invalid as "WA"
0
6. Number of Signatures found invalid as "WS"
0
7. Total Number of Invalid Signatures (add 4, 5 and 6)
0
8. Total number of duplicate signatures
0
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
0
Page 102 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
581a
SC101805 Appeal Document Number 26 Page 104
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
St. Louis County
U.S. Representative District 1
1. Number of Signatures found valid as "R"
14376
2. Number of signatures found valid as "RDA"
748
3. Total Number of Valid Signatures (add 1 and 2)
15124
4. Number of Signatures found invalid as "NR"
5131
5. Number of Signatures found invalid as "WA"
91
6. Number of Signatures found invalid as "WS"
487
7. Total Number of Invalid Signatures (add 4, 5 and 6)
5709
8. Total number of duplicate signatures
424
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
21257
U.S. Representative District 2
1. Number of Signatures found valid as "R"
22051
2. Number of signatures found valid as "RDA"
551
3. Total Number of Valid Signatures (add 1 and 2)
22602
4. Number of Signatures found invalid as "NR"
0
5. Number of Signatures found invalid as "WA"
0
6. Number of Signatures found invalid as "WS"
727
7. Total Number of Invalid Signatures (add 4, 5 and 6)
727
8. Total number of duplicate signatures
628
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
23957
Page 103 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
582a
SC101805 Appeal Document Number 26 Page 105
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
St. Louis City County
U.S. Representative District 1
1. Number of Signatures found valid as "R"
8417
2. Number of signatures found valid as "RDA"
548
3. Total Number of Valid Signatures (add 1 and 2)
8965
4. Number of Signatures found invalid as "NR"
1532
5. Number of Signatures found invalid as "WA"
223
6. Number of Signatures found invalid as "WS"
229
7. Total Number of Invalid Signatures (add 4, 5 and 6)
1984
8. Total number of duplicate signatures
229
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
11178
Page 104 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
583a
SC101805 Appeal Document Number 26 Page 106
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
Ste. Genevieve County
U.S. Representative District 8
1. Number of Signatures found valid as "R"
0
2. Number of signatures found valid as "RDA"
0
3. Total Number of Valid Signatures (add 1 and 2)
0
4. Number of Signatures found invalid as "NR"
0
5. Number of Signatures found invalid as "WA"
0
6. Number of Signatures found invalid as "WS"
0
7. Total Number of Invalid Signatures (add 4, 5 and 6)
0
8. Total number of duplicate signatures
0
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
0
Page 105 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
584a
SC101805 Appeal Document Number 26 Page 107
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
Stoddard County
U.S. Representative District 8
1. Number of Signatures found valid as "R"
32
2. Number of signatures found valid as "RDA"
0
3. Total Number of Valid Signatures (add 1 and 2)
32
4. Number of Signatures found invalid as "NR"
2
5. Number of Signatures found invalid as "WA"
4
6. Number of Signatures found invalid as "WS"
0
7. Total Number of Invalid Signatures (add 4, 5 and 6)
6
8. Total number of duplicate signatures
0
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
38
Page 106 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
585a
SC101805 Appeal Document Number 26 Page 108
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
Stone County
U.S. Representative District 7
1. Number of Signatures found valid as "R"
806
2. Number of signatures found valid as "RDA"
17
3. Total Number of Valid Signatures (add 1 and 2)
823
4. Number of Signatures found invalid as "NR"
128
5. Number of Signatures found invalid as "WA"
7
6. Number of Signatures found invalid as "WS"
25
7. Total Number of Invalid Signatures (add 4, 5 and 6)
160
8. Total number of duplicate signatures
11
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
994
Page 107 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
586a
SC101805 Appeal Document Number 26 Page 109
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
Sullivan County
U.S. Representative District 6
1. Number of Signatures found valid as "R"
16
2. Number of signatures found valid as "RDA"
0
3. Total Number of Valid Signatures (add 1 and 2)
16
4. Number of Signatures found invalid as "NR"
2
5. Number of Signatures found invalid as "WA"
1
6. Number of Signatures found invalid as "WS"
0
7. Total Number of Invalid Signatures (add 4, 5 and 6)
3
8. Total number of duplicate signatures
0
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
19
Page 108 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
587a
SC101805 Appeal Document Number 26 Page 110
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
Taney County
U.S. Representative District 7
1. Number of Signatures found valid as "R"
1326
2. Number of signatures found valid as "RDA"
106
3. Total Number of Valid Signatures (add 1 and 2)
1432
4. Number of Signatures found invalid as "NR"
279
5. Number of Signatures found invalid as "WA"
52
6. Number of Signatures found invalid as "WS"
78
7. Total Number of Invalid Signatures (add 4, 5 and 6)
409
8. Total number of duplicate signatures
23
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
1864
Page 109 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
588a
SC101805 Appeal Document Number 26 Page 111
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
Texas County
U.S. Representative District 8
1. Number of Signatures found valid as "R"
0
2. Number of signatures found valid as "RDA"
0
3. Total Number of Valid Signatures (add 1 and 2)
0
4. Number of Signatures found invalid as "NR"
0
5. Number of Signatures found invalid as "WA"
0
6. Number of Signatures found invalid as "WS"
0
7. Total Number of Invalid Signatures (add 4, 5 and 6)
0
8. Total number of duplicate signatures
0
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
0
Page 110 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
589a
SC101805 Appeal Document Number 26 Page 112
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
Vernon County
U.S. Representative District 4
1. Number of Signatures found valid as "R"
183
2. Number of signatures found valid as "RDA"
13
3. Total Number of Valid Signatures (add 1 and 2)
196
4. Number of Signatures found invalid as "NR"
26
5. Number of Signatures found invalid as "WA"
3
6. Number of Signatures found invalid as "WS"
4
7. Total Number of Invalid Signatures (add 4, 5 and 6)
33
8. Total number of duplicate signatures
2
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
231
Page 111 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
590a
SC101805 Appeal Document Number 26 Page 113
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
Warren County
U.S. Representative District 2
1. Number of Signatures found valid as "R"
316
2. Number of signatures found valid as "RDA"
6
3. Total Number of Valid Signatures (add 1 and 2)
322
4. Number of Signatures found invalid as "NR"
57
5. Number of Signatures found invalid as "WA"
10
6. Number of Signatures found invalid as "WS"
11
7. Total Number of Invalid Signatures (add 4, 5 and 6)
78
8. Total number of duplicate signatures
6
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
406
U.S. Representative District 3
1. Number of Signatures found valid as "R"
172
2. Number of signatures found valid as "RDA"
3
3. Total Number of Valid Signatures (add 1 and 2)
175
4. Number of Signatures found invalid as "NR"
0
5. Number of Signatures found invalid as "WA"
0
6. Number of Signatures found invalid as "WS"
8
7. Total Number of Invalid Signatures (add 4, 5 and 6)
8
8. Total number of duplicate signatures
1
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
184
Page 112 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
591a
SC101805 Appeal Document Number 26 Page 114
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
Washington County
U.S. Representative District 3
1. Number of Signatures found valid as "R"
71
2. Number of signatures found valid as "RDA"
2
3. Total Number of Valid Signatures (add 1 and 2)
73
4. Number of Signatures found invalid as "NR"
7
5. Number of Signatures found invalid as "WA"
0
6. Number of Signatures found invalid as "WS"
0
7. Total Number of Invalid Signatures (add 4, 5 and 6)
7
8. Total number of duplicate signatures
0
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
80
Page 113 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
592a
SC101805 Appeal Document Number 26 Page 115
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
Wayne County
U.S. Representative District 8
1. Number of Signatures found valid as "R"
0
2. Number of signatures found valid as "RDA"
0
3. Total Number of Valid Signatures (add 1 and 2)
0
4. Number of Signatures found invalid as "NR"
0
5. Number of Signatures found invalid as "WA"
0
6. Number of Signatures found invalid as "WS"
0
7. Total Number of Invalid Signatures (add 4, 5 and 6)
0
8. Total number of duplicate signatures
0
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
0
Page 114 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
593a
SC101805 Appeal Document Number 26 Page 116
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
Webster County
U.S. Representative District 4
1. Number of Signatures found valid as "R"
339
2. Number of signatures found valid as "RDA"
7
3. Total Number of Valid Signatures (add 1 and 2)
346
4. Number of Signatures found invalid as "NR"
130
5. Number of Signatures found invalid as "WA"
11
6. Number of Signatures found invalid as "WS"
7
7. Total Number of Invalid Signatures (add 4, 5 and 6)
148
8. Total number of duplicate signatures
8
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
502
U.S. Representative District 7
1. Number of Signatures found valid as "R"
239
2. Number of signatures found valid as "RDA"
2
3. Total Number of Valid Signatures (add 1 and 2)
241
4. Number of Signatures found invalid as "NR"
0
5. Number of Signatures found invalid as "WA"
0
6. Number of Signatures found invalid as "WS"
5
7. Total Number of Invalid Signatures (add 4, 5 and 6)
5
8. Total number of duplicate signatures
4
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
250
Page 115 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
594a
SC101805 Appeal Document Number 26 Page 117
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
Worth County
U.S. Representative District 6
1. Number of Signatures found valid as "R"
6
2. Number of signatures found valid as "RDA"
0
3. Total Number of Valid Signatures (add 1 and 2)
6
4. Number of Signatures found invalid as "NR"
0
5. Number of Signatures found invalid as "WA"
0
6. Number of Signatures found invalid as "WS"
0
7. Total Number of Invalid Signatures (add 4, 5 and 6)
0
8. Total number of duplicate signatures
0
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
6
Page 116 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
595a
SC101805 Appeal Document Number 26 Page 118
County:
All
Signature Totals By County
Username: SOS\paules
Petition Name: People Not Politicians
Date: 08/06/2026
Report No: PM-007
Petition Type: Referendum
Wright County
U.S. Representative District 8
1. Number of Signatures found valid as "R"
2
2. Number of signatures found valid as "RDA"
0
3. Total Number of Valid Signatures (add 1 and 2)
2
4. Number of Signatures found invalid as "NR"
0
5. Number of Signatures found invalid as "WA"
0
6. Number of Signatures found invalid as "WS"
0
7. Total Number of Invalid Signatures (add 4, 5 and 6)
0
8. Total number of duplicate signatures
3
9. Total number of valid signatures - rejected pages
0
10. Total number of invalid signatures - rejected pages
0
11. Total Number of Signatures Checked (add 3 and 7-10)
5
Page Range(s):
2026-R004-001-031511 - 2026-R004-510-009429
Page 117 of 117
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
596a
SC101805 Appeal Document Number 26 Page 119
597a
Stipulated Exhibit 5
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
SC101805 Appeal Document Number 27 Page 1
598a
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
SC101805 Appeal Document Number 27 Page 2
599a
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
SC101805 Appeal Document Number 27 Page 3
600a
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
SC101805 Appeal Document Number 27 Page 4
601a
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
SC101805 Appeal Document Number 27 Page 5
602a
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
SC101805 Appeal Document Number 27 Page 6
603a
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
SC101805 Appeal Document Number 27 Page 7
604a
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
SC101805 Appeal Document Number 27 Page 8
605a
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
SC101805 Appeal Document Number 27 Page 9
606a
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
SC101805 Appeal Document Number 27 Page 10
607a
Stipulated Exhibit 6
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
SC101805 Appeal Document Number 28 Page 1
608a
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
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
SC101805 Appeal Document Number 28 Page 2
Case: 4:25-cv-01535
Doc. #: 1
Filed: 10/15/25
Page: 2 of 24 PageID #: 2
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
2
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
609a
SC101805 Appeal Document Number 28 Page 3
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
3
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
610a
SC101805 Appeal Document Number 28 Page 4
Case: 4:25-cv-01535
Doc. #: 1
Filed: 10/15/25
Page: 4 of 24 PageID #: 4
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.
4
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
611a
SC101805 Appeal Document Number 28 Page 5
Case: 4:25-cv-01535
13.
Doc. #: 1
Filed: 10/15/25
Page: 5 of 24 PageID #: 5
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.
5
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
612a
SC101805 Appeal Document Number 28 Page 6
Case: 4:25-cv-01535
20.
Doc. #: 1
Filed: 10/15/25
Page: 6 of 24 PageID #: 6
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.
6
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
613a
SC101805 Appeal Document Number 28 Page 7
Case: 4:25-cv-01535
28.
Doc. #: 1
Filed: 10/15/25
Page: 7 of 24 PageID #: 7
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.
7
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
614a
SC101805 Appeal Document Number 28 Page 8
Case: 4:25-cv-01535
II.
Doc. #: 1
Filed: 10/15/25
Page: 8 of 24 PageID #: 8
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
8
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
615a
SC101805 Appeal Document Number 28 Page 9
Case: 4:25-cv-01535
39.
Doc. #: 1
Filed: 10/15/25
Page: 9 of 24 PageID #: 9
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
9
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
616a
SC101805 Appeal Document Number 28 Page 10
Case: 4:25-cv-01535
III.
Doc. #: 1
Filed: 10/15/25
Page: 10 of 24 PageID #: 10
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
10
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
617a
SC101805 Appeal Document Number 28 Page 11
Case: 4:25-cv-01535
Doc. #: 1
Filed: 10/15/25
Page: 11 of 24 PageID #: 11
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,
11
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
618a
SC101805 Appeal Document Number 28 Page 12
Case: 4:25-cv-01535
Doc. #: 1
Filed: 10/15/25
Page: 12 of 24 PageID #: 12
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
12
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
619a
SC101805 Appeal Document Number 28 Page 13
Case: 4:25-cv-01535
Doc. #: 1
Filed: 10/15/25
Page: 13 of 24 PageID #: 13
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
13
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
620a
SC101805 Appeal Document Number 28 Page 14
Case: 4:25-cv-01535
Doc. #: 1
Filed: 10/15/25
Page: 14 of 24 PageID #: 14
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,
14
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
621a
SC101805 Appeal Document Number 28 Page 15
Case: 4:25-cv-01535
Doc. #: 1
Filed: 10/15/25
Page: 15 of 24 PageID #: 15
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.
15
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
622a
SC101805 Appeal Document Number 28 Page 16
Case: 4:25-cv-01535
Doc. #: 1
Filed: 10/15/25
Page: 16 of 24 PageID #: 16
‘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
16
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
623a
SC101805 Appeal Document Number 28 Page 17
Case: 4:25-cv-01535
Doc. #: 1
Filed: 10/15/25
Page: 17 of 24 PageID #: 17
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).
17
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
624a
SC101805 Appeal Document Number 28 Page 18
Case: 4:25-cv-01535
58.
Doc. #: 1
Filed: 10/15/25
Page: 18 of 24 PageID #: 18
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.
18
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
625a
SC101805 Appeal Document Number 28 Page 19
Case: 4:25-cv-01535
Doc. #: 1
Filed: 10/15/25
State Leg. at 837 (Roberts, C.J., dissenting).
Page: 19 of 24 PageID #: 19
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
19
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
626a
SC101805 Appeal Document Number 28 Page 20
Case: 4:25-cv-01535
Doc. #: 1
Filed: 10/15/25
Page: 20 of 24 PageID #: 20
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
20
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
627a
SC101805 Appeal Document Number 28 Page 21
Case: 4:25-cv-01535
Doc. #: 1
Filed: 10/15/25
Page: 21 of 24 PageID #: 21
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.
21
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
628a
SC101805 Appeal Document Number 28 Page 22
Case: 4:25-cv-01535
72.
Doc. #: 1
Filed: 10/15/25
Page: 22 of 24 PageID #: 22
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.
22
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
629a
SC101805 Appeal Document Number 28 Page 23
Case: 4:25-cv-01535
Dated: October 15, 2025
Doc. #: 1
Filed: 10/15/25
Page: 23 of 24 PageID #: 23
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
23
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
630a
SC101805 Appeal Document Number 28 Page 24
Case: 4:25-cv-01535
Doc. #: 1
Filed: 10/15/25
Page: 24 of 24 PageID #: 24
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
24
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
631a
SC101805 Appeal Document Number 28 Page 25
632a
Stipulated Exhibit 7
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
SC101805 Appeal Document Number 29 Page 1
633a
Case: 4:25-cv-01535
Doc. #: 2
Filed: 10/15/25
Page: 1 of 3 PageID #: 32
IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF MISSOURI
EASTERN DIVISION
MISSOURI GENERAL ASSEMBLY, ET AL.,
Plaintiffs,
v.
Case No.
RICHARD VON GLAHN, ET AL.,
Defendants.
MOTION FOR A PRELIMINARY INJUNCTION
Plaintiffs, the Missouri General Assembly, Denny Hoskins in his official
capacity as Missouri Secretary of State, and the State of Missouri, respectfully move
this Court for a preliminary injunction under Federal Rule of Civil Procedure 65,
prohibiting Defendants Richard von Glahn and People Not Politicians from
submitting a petition for referendum on the General Assembly’s recent congressional
redistricting to the Missouri Secretary of State. For the reasons explained in the
accompanying memorandum in support of this motion, the Court should issue the
preliminary injunction against Defendants.
To prevent irreparable harm to Plaintiffs’ interests, Plaintiffs respectfully
request that this Court set an expedited briefing and hearing schedule and issue a
preliminary injunction no later than November 15, 2025.
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
SC101805 Appeal Document Number 29 Page 2
Case: 4:25-cv-01535
Dated: October 15, 2025
Doc. #: 2
Filed: 10/15/25
Page: 2 of 3 PageID #: 33
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
2
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
634a
SC101805 Appeal Document Number 29 Page 3
Case: 4:25-cv-01535
Doc. #: 2
Filed: 10/15/25
Page: 3 of 3 PageID #: 34
CERTIFICATE OF SERVICE AND COMPLIANCE
I hereby certify that true and correct copies of this Motion for Preliminary
Injunction and accompanying papers shall be served along with the Complaint in
accordance with Federal Rule of Civil Procedure 4. I further certify that the foregoing
document contains 117 words, exclusive of matters designated for omission.
s/ Louis J. Capozzi III
3
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
635a
SC101805 Appeal Document Number 29 Page 4
636a
Stipulated Exhibit 8
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
SC101805 Appeal Document Number 30 Page 1
637a
Case: 4:25-cv-01535-ZMB
Doc. #: 39 Filed: 12/08/25
1736
Page: 1 of 11 PageID #:
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.
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
SC101805 Appeal Document Number 30 Page 2
Case: 4:25-cv-01535-ZMB
Doc. #: 39 Filed: 12/08/25
1737
Page: 2 of 11 PageID #:
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.
2
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
638a
SC101805 Appeal Document Number 30 Page 3
Case: 4:25-cv-01535-ZMB
Doc. #: 39 Filed: 12/08/25
1738
Page: 3 of 11 PageID #:
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
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
639a
SC101805 Appeal Document Number 30 Page 4
Case: 4:25-cv-01535-ZMB
III.
Doc. #: 39 Filed: 12/08/25
1739
Page: 4 of 11 PageID #:
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
4
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
640a
SC101805 Appeal Document Number 30 Page 5
Case: 4:25-cv-01535-ZMB
Doc. #: 39 Filed: 12/08/25
1740
Page: 5 of 11 PageID #:
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
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
641a
SC101805 Appeal Document Number 30 Page 6
Case: 4:25-cv-01535-ZMB
I.
Doc. #: 39 Filed: 12/08/25
1741
Page: 6 of 11 PageID #:
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
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
642a
SC101805 Appeal Document Number 30 Page 7
Case: 4:25-cv-01535-ZMB
Doc. #: 39 Filed: 12/08/25
1742
Page: 7 of 11 PageID #:
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.
7
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
643a
SC101805 Appeal Document Number 30 Page 8
Case: 4:25-cv-01535-ZMB
Doc. #: 39 Filed: 12/08/25
1743
Page: 8 of 11 PageID #:
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
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
644a
SC101805 Appeal Document Number 30 Page 9
Case: 4:25-cv-01535-ZMB
II.
Doc. #: 39 Filed: 12/08/25
1744
Page: 9 of 11 PageID #:
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
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
645a
SC101805 Appeal Document Number 30 Page 10
Case: 4:25-cv-01535-ZMB
Doc. #: 39
Filed: 12/08/25
1745
Page: 10 of 11 PageID #:
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
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
646a
SC101805 Appeal Document Number 30 Page 11
Case: 4:25-cv-01535-ZMB
Doc. #: 39
Filed: 12/08/25
1746
Page: 11 of 11 PageID #:
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
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
647a
SC101805 Appeal Document Number 30 Page 12
648a
Stipulated Exhibit 9
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
SC101805 Appeal Document Number 31 Page 1
649a
Case: 4:25-cv-01535-ZMB
Doc. #: 46 Filed: 01/05/26
1823
Page: 1 of 3 PageID #:
IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF MISSOURI
EASTERN DIVISION
MISSOURI GENERAL ASSEMBLY, ET AL.,
Plaintiffs,
v.
Case No. 4:25-cv-01535-ZMB
RICHARD VON GLAHN, ET AL.,
Defendants.
STATE OF MISSOURI’S
MOTION TO ALTER THE JUDGMENT
Plaintiffs, the Missouri General Assembly, Denny Hoskins in his official
capacity as Missouri Secretary of State, and the State of Missouri, respectfully move
this Court to alter its December 8, 2025 judgment (ECF 39) pursuant to Federal Rule
of Civil Procedure 59. For the reasons explained in the accompanying memorandum
in support of this motion, Missouri respectfully requests this Court alter its judgment,
specifically for this Court to vacate its judgment based on Defendants’ counsels’
potential ethical lapses, see ECF 41-1, and based on state court cases illustrating
Missouri faced and is facing a legally cognizable harm. At a minimum, this Court
should hold this case in abeyance to see if this harm materializes and vacate the
alternative Pullman holding based on the State lacking an available state law
remedy.
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
SC101805 Appeal Document Number 31 Page 2
Case: 4:25-cv-01535-ZMB
Dated: January 5, 2026
Doc. #: 46 Filed: 01/05/26
1824
Page: 2 of 3 PageID #:
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
2
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
650a
SC101805 Appeal Document Number 31 Page 3
Case: 4:25-cv-01535-ZMB
Doc. #: 46 Filed: 01/05/26
1825
Page: 3 of 3 PageID #:
CERTIFICATE OF SERVICE
I hereby certify that on January 5, 2026 the foregoing was filed electronically
through the Court’s electronic filing system to be served electronically on counsel for
all parties.
/s/ Louis J. Capozzi III
3
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
651a
SC101805 Appeal Document Number 31 Page 4
Case: 4:25-cv-01535-ZMB
Doc. #: 47 Filed: 01/05/26
1826
Page: 1 of 13 PageID #:
IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF MISSOURI
EASTERN DIVISION
MISSOURI GENERAL ASSEMBLY, et al.
Plaintiffs,
v.
Case No. 4:25-cv-01535-ZMB
RICHARD VON GLAHN, et al.
Defendants.
MEMORANDUM IN SUPPORT OF THE STATE OF MISSOURI’S
MOTION TO ALTER THE JUDGMENT
1
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
652a
SC101805 Appeal Document Number 31 Page 5
Case: 4:25-cv-01535-ZMB
Doc. #: 47 Filed: 01/05/26
1827
Page: 2 of 13 PageID #:
INTRODUCTION
The Court dismissed the State’s case because of the “critical[]” concessions
Defendants made and because the Secretary of State has a “unique self-help remedy.”
Op. 1, 7. In an alternative holding, the Court dismissed the State’s case based on
Pullman abstention. See id. at 9–10. This Court should alter its judgment, pursuant
to Rule 59, for three reasons.
First, Defendants made two concessions at the hearing in this case: House Bill
1 is not frozen until the Secretary’s certification decision and the Secretary will have
the right to obtain judicial review under the U.S. Constitution’s Elections Clause. See
Tr. 44:15–20, 48:9–23; accord op. at 1. Defendants and their counsel have already
backtracked on the first concession.
Their misrepresentations to the Court are
sufficient reasons to alter this Court’s judgment. See ECF 41-1. Even ignoring the
ethical ramifications of Defendants’ counsels’ potential lack of candor, Defendants’
having backtracked on H.B. 1 going into effect means that the State was and is facing
an irreparable injury sufficient to confer standing. See Compl. ¶ 48; PI Br. at 11; Pls.
PI Reply and MTD Opp. Br. at 16–19.
Second, with respect to this Court, the Court’s understanding of state law may
have been incorrect such that the State has no ability to use its “unique self-help
remedy.” ECF at 7. State appellate courts have suggested the Secretary cannot reject
a proposed referendum on federal constitutional grounds. See Mo. Elec. Coop. v.
Kander, 497 S.W.3d 905, 920 (Mo. Ct. App. 2016).
And although Defendants
acknowledge they conceded otherwise, see ECF 42 at 10, that is thin comfort to the
2
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
653a
SC101805 Appeal Document Number 31 Page 6
Case: 4:25-cv-01535-ZMB
Doc. #: 47 Filed: 01/05/26
1828
Page: 3 of 13 PageID #:
State. The State is already facing a lawsuit despite Defendants’ concession that H.B.
1 would not be frozen until the Secretary’s certification decision. See Pet., Maggard
v. State of Missouri, 25AC-CC09120 (Mo. 19th Cir. Ct. Dec. 23, 2025). That lawsuit—
in which Defendants are conspicuously absent despite publicly promising to sue—
shows that the State will likely face a lawsuit as soon as the Secretary potentially
rejects the referendum, and that Defendants can avoid the consequences of their
concession to this Court by absenting themselves. Thus, to the extent this Court
believed that Defendants’ concessions would protect the State from the imminent
injuries it alleged, subsequent events have cast substantial doubt on that point. The
Court should thus reconsider whether the State faces imminent and ongoing injuries
or, at the very least, hold this case in abeyance to see if the State’s feared injuries
materialize.
Third, the Court’s Pullman abstention holding is, respectfully, mistaken.
What state law means in Elections Clause cases is a federal question.
Harper, 600 U.S. 1, 19–26 (2023).
See Moore v.
And Pullman abstention is not available on
questions of federal law. Additionally, abstention is inequitable under the Eighth
Circuit’s decision in Beavers. See Beavers v. Ark. State Bd. of Dental Exam’rs, 151
F.3d 838, 841 (8th Cir. 1998). At a minimum, abstention is only available if there is
“an adequate state remedy.” Id. Once again, state appellate authority suggests the
state courts might not allow the Secretary to reject the proposed referendum under
the federal constitution, and that they would not review that problem until after the
vote—by which time the State will have been unable to use its duly-enacted
3
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
654a
SC101805 Appeal Document Number 31 Page 7
Case: 4:25-cv-01535-ZMB
Doc. #: 47 Filed: 01/05/26
1829
Page: 4 of 13 PageID #:
congressional map for the 2026 elections. Thus, under Beavers, abstention is not
permissible in this case.
Therefore, this Court should vacate its dismissal order or, at a minimum, hold
the case in abeyance instead of dismissing. Additionally, the Court should vacate its
alternative Pullman holding.
BACKGROUND
After Missouri filed this lawsuit seeking preliminary relief and Defendants
filed their motion to dismiss, this Court held a hearing on both motions on November
25, 2025. In that hearing, the Court honed in on one of Plaintiffs’ primary alleged
harms—that the congressional map enacted in H.B. 1 could be frozen due to
Defendants’ actions. Compl. ¶ 48; PI Br. at 11. That discussion focused on the
meaning of the Missouri Constitution, which states that, as part of the referendum
process, “[a]ny measure referred to the people shall take effect when approved by a
majority of the votes cast thereon, and not otherwise.” Mo. Const. art. III, § 52(b).
When H.B. 1 would become frozen was a large focus of the hearing with the
Court pointedly questioning both sides about when the new congressional map would
be frozen. Ultimately, “everybody wound up” agreeing that the map stays in effect
unless and until a state court orders the Secretary to certify the referendum. Tr.
52:15–53:1. The Court deemed that point “abundantly clear.” Tr. 52:24.
On December 8, the Court issued its ruling dismissing Plaintiffs’ claim because
their injuries were not ripe for adjudication, see op. at 5–8, and alternatively that
Pullman abstention warrants dismissal, see id. at 9–11. The Court’s analysis relied
4
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
655a
SC101805 Appeal Document Number 31 Page 8
Case: 4:25-cv-01535-ZMB
Doc. #: 47 Filed: 01/05/26
1830
Page: 5 of 13 PageID #:
on Defendants’ “critical[]” concessions that the State did not imminently face the
harm of having its duly enacted law frozen. Id. at 1.
On December 9, Defendants submitted their referendum to the Secretary of
State. Defendants and Defendants’ counsel immediately began declaring that H.B. 1
was “suspended” until after Missourians voted to approve or reject it. 1 The ethical
ramifications of Defendants’ counsel potentially breaching their duty of candor to this
Court is subject to another motion. See ECF 41.
On December 23, two Missourians filed a petition in Missouri state court
seeking declaratory and injunctive relief against the State of Missouri and Secretary
Hoskins based on Defendants’ referendum petition. See Pet., Maggard v. State of
Missouri, 25AC-CC09120 (Mo. 19th Cir. Ct. Dec. 23, 2025). Their one count alleges
that Secretary Hoskins incorrectly put H.B. 1 into effect because Defendants have
submitted their referendum petition. See id. ¶¶ 31–37. Petitioners seek a declaration
that “HB1 is suspended until voters approve or reject it” and an injunction
“prohibiting the use of HB1’s new congressional map before voters approve or reject
1 Rudi Keller & Jason Hancock, Missouri Set to Enact Gerrymandered Map Despite
300K Signatures for Repeal Referendum, Missouri Independent (Dec. 9, 2025),
https://missouriindependent.com/2025/12/09/missouri-gerrymander-congressionalmap-referendum/; see also Alisa Nelson, When Does Missouri’s New Congressional
Map Take Effect? That Depends on Who You Ask, Missourinet (Dec. 10, 2025),
https://www.missourinet.com/2025/12/10/when-does-missouris-new-congressionalmap-take-effect-that-depends-on-who-you-ask/ (quoting People Not Politicians press
release).
5
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
656a
SC101805 Appeal Document Number 31 Page 9
Case: 4:25-cv-01535-ZMB
Doc. #: 47 Filed: 01/05/26
1831
Page: 6 of 13 PageID #:
it.” Id. ¶¶ 43–44. Despite Defendants’ public promises to file that same lawsuit, 2
they are conspicuously (and at least nominally) absent from the Maggard case.
ARGUMENT
The Court should alter its judgment. This Court has broad discretion to grant
a Rule 59(e) motion, including “the need to correct a clear error or prevent manifest
injustice.”
Firestone v. Firestone, 76 F.3d 1205, 1208 (D.C. Cir. 1996) (citation
omitted).
I.
Defendants backtracking on their concessions show that
Plaintiffs have standing. The Court should vacate its opinion.
Defendants’ Counsel made two concessions at the hearing in this case: (1) that
H.B. 1 is not frozen until the Secretary’s certification decision and (2) that the
Secretary will have the right to obtain judicial review under the U.S. Constitution’s
Elections Clause. See Tr. 44:15–20, 48:9–23; accord op. at 1. In the Court’s words,
these concessions were “critical[]” in its determination that this case was not ripe for
adjudication. Op. at 1.
See
Press
Release,
People
Not
Politicians
(Dec.
9,
2025),
https://peoplenotpoliticiansmo.org/missouri-voters-mobilize-in-defense-of-coredemocratic-rights-with-historic-referendum-submission-halting-missouris-supergerrymander/ (“If the Secretary of State refuses to certify the referendum or attempts
to put HB1 into effect prematurely, People Not Politicians is prepared to take
immediate action in state court.”); Jason Rosenbaum, Missouri redistricting foes may
have dealt a big blow to Trump-backed congressional map, St. Louis Public Radio
(Dec. 9, 2025), https://www.krcu.org/news/2025-12-09/missouri-redistricting-foesmay-have-dealt-big-blow-to-trump-backed-congressional-map (“Hatfield agreed that
if a court finds that Hoskins and Hanaway are wrong that the map wasn’t frozen as
soon as People Not Politicians turned in their signatures, then there’s no way for the
map to go into effect during the 2026 election cycle. ‘If it turns out that they’re going
to make us go to court on every single step of this process, I guess that’s what we’ll
do,’ he said.”).
2
6
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
657a
SC101805 Appeal Document Number 31 Page 10
Case: 4:25-cv-01535-ZMB
Doc. #: 47 Filed: 01/05/26
1832
Page: 7 of 13 PageID #:
As highlighted in Plaintiffs’ suggestions and reply in support of their motion
for sanctions, Defendants (and Defendants’ counsel) have backtracked on their
concessions made to this Court. See ECF 41-1 at 3–8; ECF 43 at 2–3. After this
Court’s ruling, Defendants have unequivocally stated their new—or rather honest—
position that H.B. 1 “must be paused until Missourians vote on it.” 3 If, as Defendants
and their counsel now claim, submitting their referendum is sufficient to suspend
H.B. 1, then their “critical[]” concession to this Court is meaningless. Op. at 1. As
Plaintiffs explained and argued in their motion for sanctions, that is enough for this
Court to set aside its previous judgment. See ECF 41-1 at 11; see also Hazel-Atlas
Glass Co. v. Hartford-Empire Co., 322 U.S. 238, 245 (1944) (setting aside fraudulently
begotten judgment based on Defendant’s misrepresentations).
Regardless of the possible ethical ramifications for Defendants’ counsel,
Defendants backtracking on their concessions reinforces the reality that the State
has standing in this case. See Compl. ¶ 48; PI Br. 10–11. If Defendants’ mere
submission of their referendum—without counting signatures, much less verifying
their legitimacy—suspended H.B. 1, then the State would be “barr[ed] . . . from
conducting this year’s elections pursuant to a statute enacted by the Legislature . . .
3 Alisa Nelson, When
Does Missouri’s New Congressional Map Take Effect? That
Depends
on
Who
You
Ask,
Missourinet
(Dec.
10,
2025),
https://www.missourinet.com/2025/12/10/when-does-missouris-new-congressionalmap-take-effect-that-depends-on-who-you-ask/ (quoting People Not Politicians press
release); Jason Rosenbaum, Missouri Redistricting Foes May Have Dealt Big Blow to
Trump-Backed Congressional Map, St. Louis Public Radio (Dec. 9, 2025),
https://www.stlpr.org/government-politics-issues/2025-12-09/missouri-redistrictingfoes-may-have-dealt-big-blow-to-trump-backed-congressional-map.
7
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
658a
SC101805 Appeal Document Number 31 Page 11
Case: 4:25-cv-01535-ZMB
Doc. #: 47 Filed: 01/05/26
1833
Page: 8 of 13 PageID #:
[T]his would seriously and irreparably harm the State.” Abbott v. Perez, 585 U.S.
579, 602 (2018). Therefore, to prevent manifest injustice of relying on Defendants’
spurious concessions seemingly suggesting that the Secretary and Plaintiffs could
obviate this “serious[] and irreparabl[e] harm,” this Court should reconsider whether
the State has standing and alter its judgment accordingly.
II.
Regardless
of
Defendants’
concessions,
the
Court’s
understanding that the State could forestall harm through
rejecting the referendum petition is dubious. So the Court
should hold this case in abeyance.
Regardless of Defendants’ concessions, in denying Plaintiffs standing, this
Court understood Missouri law to (1) require displacement of H.B. 1 only “[i]f the
Secretary finds the petition satisfies both” compliance with the Missouri Constitution
and the signature requirements, op. at 2 (citing Mo. Rev. Stat. § 116.150), and
(2) allow the Secretary to reject the referendum on federal constitutional grounds, op
at 8. The State has already been sued on the first question. See Pet., Maggard v.
State of Missouri, 25AC-CC09120 (Mo. 19th Cir. Ct. Dec. 23, 2025). And with all due
respect to this Court, the second point is dubious as a matter of state law.
Despite the Court holding that Secretary Hoskins has the “unique self-help
remedy” through his “power to declare the petition unconstitutional,” op. at 7,
Missouri law seemingly suggests the Secretary cannot reject a referendum under the
U.S. Constitution, see Calzone v. Ashcroft, 559 S.W.3d 32, 37 (Mo. Ct. App. 2018). As
the Western District Court of Appeals explained in Missouri Electric Cooperatives v.
Kander, the legal “sufficiency determination the Secretary of State is required to
conduct plainly does not include whether an initiative petition complies with the
8
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
659a
SC101805 Appeal Document Number 31 Page 12
Case: 4:25-cv-01535-ZMB
Doc. #: 47 Filed: 01/05/26
1834
Page: 9 of 13 PageID #:
Federal Constitution” 497 S.W.3d at 920 (emphasis in original). With respect to the
Court, it may have been wrong on this point central to its holding. If the Secretary
declares the referendum petition to violate the Elections Clause, the State will face
an immediate lawsuit in courts that will be bound by cases like Missouri Electric
Cooperatives.
Moreover, the State is skeptical that Defendants’ contrary concession will do it
any good. Defendants have already renounced their concession that H.B. 1 is not
immediately frozen by the mere submission of signatures. 4
And after they
encouraged litigation against the State on that question, random voters with an elite
legal team suddenly appeared and sought the very relief that Plaintiffs alleged would
inflict irreparable harm on the State—a suspension of the General Assembly’s
enacted congressional districts. See Compl. ¶ 48. Given the fact that this Court
suggested Defendants would be estopped from bringing such a suit, op. at 7 n.4, it is
hard not to wonder whether Defendants are absent from that litigation precisely to
avoid that consequence.
Maggard reinforces that Defendants’ concessions on the Secretary’s ability to
prevent the State’s alleged harms in this case offer little protection. Independent
third parties are not bound by whatever concessions Defendants made or this Court’s
judgment. See Feinstein v. Edward Livingston & Sons, Inc., 457 S.W.2d 789, 794 (Mo.
banc 1970). 5 And the fact that Maggard was filed without Defendants being the
4 See Keller, supra note 1; Nelson, supra note 1.
The State is not conceding that Defendants played no role in the filing of the
Maggard case.
5
9
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
660a
SC101805 Appeal Document Number 31 Page 13
Case: 4:25-cv-01535-ZMB
Doc. #: 47
Filed: 01/05/26
1835
Page: 10 of 13 PageID #:
initiating parties suggests that nothing will stop third parties from arguing that
(1) the Secretary cannot reject proposed referenda on substantive constitutional
grounds and that (2) state court judicial review is not available until after the final
vote.
At a minimum, recent events should make the Court question whether
Defendants’ concessions will actually help prevent the State from harm. Under these
circumstances, it is—at a minimum—appropriate for the Court to hold this case in
abeyance to see if Defendants’ concessions will hold up. 6
III.
The Court’s alternative Pullman holding is erroneous and
should be vacated.
Even if the Court thinks subsequent events have not undermined its standing
ruling, the State respectfully requests that this Court vacate its Pullman holding.
First, Plaintiffs’ lawsuit raises a pure federal question, making Pullman
abstention categorically unavailable. What state law means in Elections Clause
cases is a federal question. See Moore, 600 U.S. at 19–26 (“The question on the merits
is whether the Elections Clause insulates state legislatures from review by state
courts for compliance with state law.”); see also id. 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 ensure that state court
interpretations of that law do not evade federal law.”); Bush v. Gore, 531 U.S. 98, 113
6 Plaintiffs sought declaratory relief, see Compl. ¶ 70, Prayer for Relief 1–2, which
prevents this case from being moot, see Thomas v. Bennett, 856 F.2d 1165, 1168 (8th
Cir. 1988). Additionally, Plaintiffs should be permitted to file a new motion for a
preliminary injunction or an amended complaint if Defendants’ concessions do not
hold up.
10
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
661a
SC101805 Appeal Document Number 31 Page 14
Case: 4:25-cv-01535-ZMB
Doc. #: 47
Filed: 01/05/26
1836
Page: 11 of 13 PageID #:
(2000) (Rehnquist, C.J., concurring) (“A significant departure from the legislative
scheme for appointing Presidential electors presents a federal constitutional
question.”). Pullman abstention is thus categorically impermissible—because federal
courts cannot abstain on questions of federal law. See Hunter v. Page Cnty., 102 F.4th
853, 873 (8th Cir. 2024).
Additionally, nearly all of the merits briefing in this case is about whether the
Elections Clause requires a clear statement rule before allowing a referendum. See
PI Br. at 3–10; Defs. MTD and PI Opp. Br. at 19–25; Pls. PI Reply and MTD Opp. Br.
at 3–12; Defs MTD Reply Br. at 10–14. The parties spend almost zero space debating
state-law rules. The answer to this case thus does not “depend[] on state courts’
construction of an ambiguous state law” making Pullman abstention inappropriate.
Hunter, 102 F.4th at 873.
Second, under the Eighth Circuit’s five-factor Beavers test, abstaining under
Pullman is inappropriate. See Beavers, 151 F.3d at 841. The second factor is whether
state remedies are “available.” Id. at 841. Again, the Court relied on Secretary
Hoskins’s ability to reject the referendum petition on Elections Clause grounds in its
ruling. Op. at 10. “[T]he only pertinent inquiry is whether the state proceedings
afford an adequate opportunity to raise the constitutional claims.” Moore v. Sims,
442 U.S. 415, 430 (1979). As explained above, they may not. The Secretary may not
be able to reject a referendum on redistricting based on federal-constitutional
grounds.
See Mo. Elec. Coops., 497 S.W.3d at 920.
And again, Defendants’
concessions only apply to them; other litigants are free (and likely) to bring a state
11
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
662a
SC101805 Appeal Document Number 31 Page 15
Case: 4:25-cv-01535-ZMB
Doc. #: 47
Filed: 01/05/26
1837
Page: 12 of 13 PageID #:
court challenge if the Secretary were to do so. Defendants’ opportunistic backtracking
on their freezing concession, and the filing of the Maggard case, reinforces the
legitimacy of that concern.
Therefore the Court should vacate its alternative Pullman holding.
CONCLUSION
For the foregoing reasons, the Court should grant Missouri’s motion to alter its
judgment pursuant to Rule 59(e).
Dated: January 5, 2026
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
12
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
663a
SC101805 Appeal Document Number 31 Page 16
Case: 4:25-cv-01535-ZMB
Doc. #: 47
Filed: 01/05/26
1838
Page: 13 of 13 PageID #:
CERTIFICATE OF SERVICE
I hereby certify that on January 5, 2026 the foregoing was filed electronically
through the Court’s electronic filing system to be served electronically on counsel for
all parties.
/s/ Louis J. Capozzi III
13
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
664a
SC101805 Appeal Document Number 31 Page 17
665a
Stipulated Exhibit 10
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
SC101805 Appeal Document Number 32 Page 1
666a
Case: 4:25-cv-01535-ZMB
Doc. #: 50 Filed: 05/11/26
1877
Page: 1 of 7 PageID #:
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 Sanctions against Defendants’
Counsel, Doc. 41, and Motion to Alter the Judgment, Doc. 46. Plaintiffs (“the State”) claim that
counsel for Defendants (“PNP”) breached their duty of candor to this Court. Doc. 41. As a sanction,
the State asks the Court to admonish counsel, vacate its dismissal order, reopen the case, and strike
PNP’s motion to dismiss. Id. at 1. The State also argues that, in dismissing this case, the Court
misapplied both state law and Pullman abstention doctrine. Doc. 47 at 2–3. While the relevant
public statements were ill advised, the Court finds that there is not clear-and-convincing evidence
of attorney misconduct and that there is no basis for altering its judgment. Accordingly, the Court
denies both motions.
BACKGROUND
The State brought this action for declaratory and injunctive relief to prevent PNP from
submitting a referendum petition to reject a recently enacted congressional-redistricting bill. Docs. 1– 2.
PNP promptly moved to dismiss and also opposed the State’s motion for preliminary injunction.
Docs. 21–22. After thorough briefing, the Court held a hearing on both motions. Doc. 38 (“Tr.”).
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
SC101805 Appeal Document Number 32 Page 2
Case: 4:25-cv-01535-ZMB
Doc. #: 50 Filed: 05/11/26
1878
Page: 2 of 7 PageID #:
During the hearing, the Court posed a series of questions to PNP’s counsel about when the
new map would go into effect. Tr. at 44–45. First, the Court asked Attorney Jessica Amunson
whether the new map “would go into effect” if the Secretary “declines to certify the petition.” Id.
at 47–48. Ms. Amunson agreed it would. Id. Later, the Court highlighted Attorney Charles
Hatfield’s endorsement of the State’s position that the “map would stay in effect unless and until
[PNP could] win a state court challenge” to a certification of insufficiency. 1 Id. at 52. Shortly after
the hearing, the Court issued an opinion granting PNP’s Motion to Dismiss on ripeness grounds.
Doc. 39. Significant to that decision was PNP’s concession that the Secretary had the authority “to
reject their petition as unconstitutional during post-submission review” and that “this
determination would obviate the need for signature verification, publication, or a vote, and it also
would prevent the displacement of the new map.” Id. at 1.
In the wake of the Court’s opinion, PNP and Mr. Hatfield made statements to the press
suggesting that the mere submission of signatures would freeze the new map, while acknowledging
that the issuance of a certificate of insufficiency would give immediate effect to the new law, subject
to any court challenge. See, e.g., Rudi Keller & Jason Hancock, Missouri Set to Enact Gerrymandered
Map Despite 300K Signatures for Repeal Referendum, MO. INDEPENDENT (Dec. 9, 2025),
https://missouriindependent.com/2025/12/09/missouri-gerrymander-congressional-map-referendum;
Jason Rosenbaum, Missouri Redistricting Foes May Have Dealt Big Blow to Trump-Backed Congressional
Map, ST. LOUIS PUB. RADIO (Dec. 9, 2025), https://www.stlpr.org/government-politics-issues/202512-09/missouri-redistricting-foes-may-have-dealt-big-blow-to-trump-backed-congressional-map.
After exchanging letters with PNP, the State filed a motion for sanctions, contending that PNP and
Mr. Hatfield contradicted PNP’s representations to the Court. Docs. 41-2, 41-3. The State also moved
to alter or amend the judgment. Doc. 46. Both motions are fully briefed. Docs. 42–45, 47–49.
At times, the Court has used “decertification” as a shorthand for “a certificate of insufficiency under MO. REV. STAT.
§ 116.150.” While the parties had no apparent trouble understanding this term at the hearing, it has become an added
source of contention. Doc. 41-1 at 10; Doc. 42 at 9. To avoid any doubt, the phrases should be treated as synonymous.
1
2
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
667a
SC101805 Appeal Document Number 32 Page 3
Case: 4:25-cv-01535-ZMB
Doc. #: 50 Filed: 05/11/26
1879
Page: 3 of 7 PageID #:
LEGAL STANDARD
District courts have the inherent power to impose sanctions for bad-faith conduct, including
abuse of the judicial process. Schlafly v. Eagle F., 970 F.3d 924, 936–37 (8th Cir. 2020). But given
“their very potency, inherent powers must be exercised with restraint and discretion.” Lupe Dev.
Partners v. Penny Baird, --- F.4th ---, 2026 WL 1252325 (8th Cir. 2026) (citation omitted). In
extreme cases involving particularly egregious misconduct, a party’s fraud on the court may justify
vacating a judgment. United States v. Smiley, 553 F.3d 1137, 1142 (8th Cir. 2009). Regardless of
the sanction, there must be “clear and convincing evidence” of misconduct, combined with a
finding “that a lesser sanction would not sufficiently punish and deter the abusive conduct.” Martin
v. DaimlerChrysler Corp., 251 F.3d 691, 694–95 (8th Cir. 2001).
An attorney practicing in this District must not knowingly make “a false statement of fact
or law to a tribunal.” MO. SUP. CT. R. 4-3.3(a); see also E.D. MO. L.R. 12.02 (adopting Missouri’s
Rules of Professional Conduct). There appears to be little authority limiting a lawyer’s public
statements after the conclusion of a case. However, attorneys generally must not issue “an
extrajudicial statement that the lawyer knows or reasonably should know will be disseminated by
means of public communication and will have a substantial likelihood of materially prejudicing an
adjudicative proceeding,” unless necessary to “protect a client from the substantial undue
prejudicial effect of recent publicity” initiated by another party. Id. 4-3.6(a), (c).
Federal Rule of Civil Procedure 59(e) permits a court to alter or amend a judgment. Such
motions “serve the limited function of correcting manifest errors of law or fact or to present newly
discovered evidence.” United States v. Metro. St. Louis Sewer Dist., 440 F.3d 930, 933 (8th Cir. 2006)
(quotation omitted). But they “cannot be used to introduce new evidence, tender new legal theories,
or raise arguments which could have been offered or raised prior to entry of judgment.” Id.
3
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
668a
SC101805 Appeal Document Number 32 Page 4
Case: 4:25-cv-01535-ZMB
Doc. #: 50 Filed: 05/11/26
1880
Page: 4 of 7 PageID #:
DISCUSSION
Invoking the Court’s inherent authority, the State seeks sanctions for public statements PNP
and its attorney made following the dismissal of this case. But while those comments pushed the
envelope, the State has not presented clear-and-convincing evidence of bad faith to justify sanctions.
Even if it had, a finding of misconduct would not change the Court’s conclusion that the State still
lacks standing to pursue its claims. See Doc. 39 at 7–8. Finally, the State’s rehashing of abstention
arguments fails to show a manifest error of law. Thus, the Court denies both of the State’s motions.
I.
Insufficient Evidence of Misrepresentation
While it was imprudent for PNP and its attorney to make public comments so closely
related to its concessions in this case while related litigation is ongoing, the State is incorrect that
the challenged statements “directly conflict[]” with counsels’ representations at the hearing. Doc.
41-1 at 12. True, the Court’s line of questioning presumed that the new map would go into effect
unless and until the Secretary determined that the petition both contained “enough valid
signatures” and otherwise complied with the Missouri Constitution. 2 Tr. at 45–52; see also Doc.
39 at 2 (collecting relevant Missouri authority). But PNP’s counsel ceded ground only in the
context of post-certification litigation. Tr. at 48, 52. In other words, the statements to the press
violated the premise of the Court’s questions but not the letter of the concessions that PNP actually
made at the hearing. As such, there is not clear and convincing evidence that PNP’s counsel
breached their duty of candor to the Court.
Indeed, the Cole County Circuit Court has since explained why PNP’s “automatic suspension” arguments fall short.
Maggard v. Missouri, No. 25AC-CC09120, Order and Final Judgement, at 11–17 (Mo. 19th Cir. Ct. Mar. 27, 2026).
And despite the State’s contention, see Doc. 44, the filing of this lawsuit by an apparently unrelated third-party is far
from the “clear and convincing” evidence necessary to impose sanctions. Moreover, given that the Maggard Court
rejected the challengers’ position, it is difficult to identify any cognizable harm the State suffered as a result of that case.
2
4
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
669a
SC101805 Appeal Document Number 32 Page 5
Case: 4:25-cv-01535-ZMB
Doc. #: 50 Filed: 05/11/26
1881
Page: 5 of 7 PageID #:
Moreover, the State shares some blame for the creation of this ambiguity in the first place.
Based on its assertion of irreparable harm, see Doc. 3-1 ¶ 14, the Court found it highly unlikely
that the State would willingly expend the time and resources on signature verification when the
Secretary could issue a certificate of insufficiency on constitutional grounds alone (particularly
when so much of the constitutional analysis was developed through this lawsuit). See Doc. 39 at 3
n.2 (“[T]here is no apparent reason why he would incur the significant cost of signature verification
given his stated belief that the petition is constitutionally deficient.”). Apparently, the Secretary
has reasons for taking a different approach. 3 But had the State indicated it might take that approach
at the hearing, or even afterward, it likely would have forced PNP to address the scenario that
occurred after dismissal.
That being said, the Court expects that this order will help PNP avoid any future foot faults.
Lest there be any remaining doubt, the Court cautions PNP’s counsel that any backtracking on
their representations to this Court regarding the new map going into effect following a certification
of insufficiency (unless and until a Missouri court overturns that decision) will result in the
imposition of sanctions. At least on the current record, however, the State has failed to offer clearand-convincing evidence that PNP has breached its duty of candor.
3
As the Court previously recognized, the Secretary has the prerogative to decide how to conduct the certification
process. Doc. 39 at 3 n.2. But that does not mean the State can have it both ways for purposes of litigation. For instance,
in seeking injunctive relief, the State relied heavily on the cost of signature verification. See, e.g., Doc. 3 at 11. Yet it
now suggests that “skipping signature verification is not prudent” because PNP may not have enough signatures. Doc.
41-1 at 13 n.11; Doc. 43 at 12. Fair enough. But the State’s election to complete signature verification before
constitutional review has seriously eroded that cost as a basis for irreparable harm. Likewise, the State’s invocation
of “constitutional avoidance” rings hollow given that the express purpose of this case is to challenge the
constitutionality of a referendum that may be resolved on a host state-law issues. See Doc. 43 at 12; Doc. 49 at 9.
5
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
670a
SC101805 Appeal Document Number 32 Page 6
Case: 4:25-cv-01535-ZMB
II.
Doc. #: 50 Filed: 05/11/26
1882
Page: 6 of 7 PageID #:
Continued Lack of Standing
The State also invites the Court to revisit its holding on standing in light of PNP’s
“backtracking” and a purported misapprehension of Missouri law. Doc. 47 at 6–10. Both
arguments fall short of justifying reconsideration.
The Court already has explained why the first point fails as a factual matter. Moreover,
even if the PNP’s public comments were sanctionable, the State is simply wrong about the legal
significance of “spurious concessions.” Id. at 8. While the Court did believe that PNP understood
and agreed with its logical reasoning about when a challenged law is in effect during the
referendum process, the Court made clear it would have reached the same conclusion on this matter
of law regardless of PNP’s position. See, e.g., Doc. 39 at 7 n.4 (“In any event, the Court’s review
of Missouri law indicates that a contrary position would plainly fail.”). And the Court’s finding
regarding ripeness is only bolstered by the Maggard Court’s intervening rejection of the claim for
“automatic suspension,” see supra at 4 n.2, which undercuts the bulk of the State’s remaining
argument on this front. But even if that court had reached the opposite conclusion, nothing would
prevent the Secretary from issuing a certificate of insufficiency, which PNP has agreed in no
uncertain terms will prevent the new map from being displaced. See, e.g., Doc. 48 at 7. Finally, as
previously explained, the existence of parallel litigation like Maggard, or future litigation that may
arise from the Secretary’s certification decision does not confer standing. See Doc. 39 at 6 n.3.
Nor is the Court moved by the State’s discussion of Missouri law. Although it was raised
for the first time at the hearing, the Court already explained why the Missouri Court of Appeals
decision in Calzone v. Ashcroft is distinguishable. Doc. 39 at 8. Likewise, the State’s newfound
reliance on Missouri Electric Cooperatives v. Kander is misplaced. Doc. 47 at 8–9 (discussing 497
S.W.3d 905 (Mo. Ct. App. 2016)). True, the Secretary’s review at the certification stage is limited
to “threshold issues that affect the integrity of the election itself, and that are so clear as to
constitute a matter of form.” Kander, 497 S.W.3d at 912. But Kander involved substantive
6
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
671a
SC101805 Appeal Document Number 32 Page 7
Case: 4:25-cv-01535-ZMB
Doc. #: 50 Filed: 05/11/26
1883
Page: 7 of 7 PageID #:
constitutional challenges to the text of the referendum petition itself. Id. at 907–10. Here, the claim
stems from a threshold issue affecting the integrity of the election as a whole. And if the
referendum is a clear violation of a bedrock constitutional principle, as the State suggests, it relates
to a matter of form, not substance. As such, it would be suitable for resolution by the Secretary at
the certification stage, making Kander inapposite. See id. at 912.
III.
Pullman Abstention
The State’s effort to relitigate Pullman abstention likewise fails. The State largely
resurrects arguments the Court already rejected. But a Rule 59(e) motion “cannot be used as a
vehicle to relitigate old issues.” Ford v. Strange, No. 1:24-CV-211-RWS, 2025 WL 2926194, at
*3 (E.D. Mo. Oct. 15, 2025) (citation omitted). And the Court already has addressed the State’s
only “new” argument regarding the potential unavailability of relief in state court under Kander. 4
See Doc. 47 at 11–12. Moreover, since this Court’s previous order, the list of parallel state court
proceedings has only grown. The Missouri Supreme Court is set to decide whether the mere
submission of the referendum petition displaced the new map. Regardless of the outcome there,
the Secretary is in the process of conducting signature verification and still must complete his
constitutional review, which will likely lead to a new round of litigation. As such, Pullman
abstention remains a valid basis for dismissing this case.
CONCLUSION
Accordingly, the Court DENIES the State’s [41] Motion for Sanctions and [46] Motion to
Alter Judgment.
So ordered this 11th day of May 2026.
ZACHARY M. BLUESTONE
UNITED STATES DISTRICT JUDGE
While the Court elected to address the merits, it notes that a Rule 59(e) motion is not a proper vehicle to “raise arguments
which could have been offered or raised prior to entry of judgment.” See Metro St. Louis Sewer Dist., 440 F.3d at 933.
4
7
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
672a
SC101805 Appeal Document Number 32 Page 8
673a
Stipulated Exhibit 11
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
SC101805 Appeal Document Number 33 Page 1
Make Your Voice Heard
Missouri’s Initiative Petition Process
Denny Hoskins, CPA
Secretary of State
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
674a
SC101805 Appeal Document Number 33 Page 2
675a
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
SC101805 Appeal Document Number 33 Page 3
Make Your Voice Heard:
Missouri’s Initiative Petition Process
Prepared by
The Missouri Secretary of State’s Office
Table of Contents
Initiative Petition Overview....................................................2
Submitting a Proposed Petition...............................................2
Circulating the Petition...........................................................3
Submitting and Checking Signatures.......................................3
Issuing the Certificate of Sufficiency.......................................4
Number of Required Signatures..............................................5
Filing Instructions and Procedures..........................................6
Missouri’s Congressional Districts. .........................................8
Congressional District Map. ...................................................9
Sample Initiative Petition Submission Cover Page. ...............10
Constitutional and Statutory Provisions. ...............................11
Code of Regulations.............................................................35
The secretary of state’s office makes every effort to provide
program accessibility to all citizens. If you desire this publication
in an alternate form because of a disability, please contact the
Elections Division, PO Box 1767, Jefferson City, MO 65102;
phone (573) 751-2301 or (800) 669-8683. Hearing-impaired
citizens may contact the Division by phone through Relay
Missouri (800) 735-2966 (TT) and (800) 735-2466 (Voice).
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
676a
SC101805 Appeal Document Number 33 Page 4
Initiative Petition Overview
The secretary of state’s office is charged with overseeing this process and
certifying proposed petitions for the ballot.
Petitioners will first submit proposed petitions to the secretary of state’s
office. The office approves the proposed petition’s form and prepares ballot
summary language. The state auditor also prepares a fiscal note and fiscal
note summary for the proposed petition. The secretary of state’s office then
certifies the official ballot title for the petition, which consists of the ballot
summary language and fiscal note summary. After the official ballot title
is certified, petitioners can circulate their proposed petitions and collect
signatures. Next, petitioners submit these signatures to the secretary of state’s
office. The office distributes petition pages to local election authorities to
verify that the signatures are those of registered Missouri voters in the correct
Congressional district. Finally, the secretary of state’s office receives the
verified signatures and determines whether the petition contains a sufficient
number of valid signatures. If so, the secretary of state’s office issues a
certificate of sufficiency, stating that the petition shall be placed on the ballot
for the general election. The details of the process are outlined below.
Submitting a Proposed Petition
Step 1: A petitioner submits a proposed petition, in the form in which it
will be circulated, and a petition submission cover sheet to the secretary of
state’s office, which issues a receipt to the petitioner. If a person or committee,
other than the petitioner, is funding a portion of the drafting or submission of
the sample sheet, the petitioner must also attach to the proposed petition a
copy of the filed statement of committee organization required under Section
130.021.5, RSMo, showing the date the statement was filed.
Step 2: The secretary of state’s office sends a copy of the proposed
petition to the attorney general’s office and the auditor’s office.
Step 3: The proposed petition is posted on the secretary of state’s office
website for a public comment period.
Step 4: The attorney general’s office reviews the form and forwards its
comments to the secretary of state’s office within 10 days after receiving the
proposed petition. The auditor’s office prepares a fiscal note and fiscal note
summary and forwards it to the attorney general’s office within 20 days after
receiving the proposed petition.
2
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
677a
SC101805 Appeal Document Number 33 Page 5
Step 5: The secretary of state’s office approves or rejects the form of the
proposed petition within 15 days after receiving the proposed petition from
the petitioner. The petitioner is informed of the approval or rejection.
Step 6: The secretary of state’s office prepares a proposed ballot summary
statement and forwards it to the attorney general’s office for review within 23
days after the approval of the proposed petition’s form.
Step 7: The attorney general’s office forwards its review to the secretary
of state’s office within 10 days after receiving the proposed ballot summary
statement. The attorney general’s office also forwards its approval or rejection
of the fiscal note and fiscal note summary to the auditor’s office within 10
days after receiving the proposed fiscal note and fiscal note summary. The
auditor’s office then forwards the fiscal note and fiscal note summary to the
secretary of state’s office.
Step 8: Within 3 days after receiving the ballot summary statement,
approved fiscal note summary and fiscal note, the secretary of state’s
office certifies the official ballot title, which consists of the ballot summary
statement and fiscal note summary. The official ballot title is then posted on
the secretary of state’s website.
Circulating the Petition
Any registered Missouri voter can sign an initiative petition. Petition
circulators, who must be at least eighteen years of age and registered
with the secretary of state’s office, collect signatures on petition pages
that contain the official ballot title and the full and correct text of the
proposed measure. Each petition page may only contain signatures of
voters from one county. Signatures of voters from counties other than the
one designated by the circulator in the upper right-hand corner of the
petition page will not be counted.
Note: Individuals that sign any name other than their own to any
petition; knowingly sign their name more than once for the same measure
for the same election; sign knowing that they are not a Missouri registered
voter; or knowingly accept or offer money or anything of value to another
person in exchange for a signature on a petition may be charged with a class
A misdemeanor.
Submitting and Checking Signatures
All petitioners must deliver signed petitions to the secretary of state’s
office no less than six months before the election. For the 2026 election cycle,
the submission deadline for signatures is 5:00 PM on May 3. Petitioners also
3
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
678a
SC101805 Appeal Document Number 33 Page 6
submit paperwork showing the number of pages per county, and contact
information for each petition. All pages of the petition must be submitted at
one time, placed in order and numbered sequentially by county, unless an
alternate numbering scheme is approved in writing by the secretary of state’s
office prior to submission. After verifying the count of signature pages, the
secretary of state’s office will issue a receipt to the petitioner.
Proposed constitutional amendments and statutory measures will be
numbered or lettered in the order in which they were passed by the general
assembly or submitted by initiative petition.
The secretary of state’s office will inventory every petition page by
county.
Petition pages are distributed to local election authorities for signature
verification. If only one petition is submitted to the secretary of state’s office,
the local election authority must receive the pages no later than two weeks
after the petition is submitted. If three petitions are submitted, the local
election authority must receive the pages no later than three weeks after the
petition is submitted. If more than three petitions are submitted, the local
election authority must receive the pages no later than four weeks after the
petition is submitted. The secretary of state’s office chooses whether to verify
every signature or use random sampling and instructions for verifying the
signatures are sent to local election authorities. If every signature is verified,
verification must be certified and delivered to the secretary of state’s office
by 5:00 PM on the last Tuesday in July prior to the election. For the 2026
election cycle, the deadline is 5:00 PM on July 28.
Issuing the Certificate of Sufficiency
Upon receiving verified signatures from each local election authority,
the secretary of state’s office determines the sufficiency of each petition by
tallying the valid signatures. For the 2026 election cycle, the number of valid
signatures needed is outlined on page 5 (Table A). If the office finds that a
sufficient number of valid signatures have been submitted on a petition,
the secretary of state issues a certificate stating that the petition contains
a sufficient number of valid signatures to comply with the Constitution of
Missouri and state law and shall be placed on the ballot. However, if the
office finds the petition insufficient, the secretary of state issues a certificate
stating the reasons for the insufficiency. The certificate must be issued before
5:00 PM on the 13th Tuesday prior to the general election or, if the signatures
were verified by random sample, two weeks after the date the local election
authority certifies the results of the verification, whichever is later.
4
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
679a
SC101805 Appeal Document Number 33 Page 7
Number of Required Signatures
Petitions proposing statutory changes must be signed by five percent of
legal voters in any six of the eight congressional districts. Petitions proposing
constitutional changes must be signed by eight percent of legal voters in any
six of the eight congressional districts. These numbers are shown in Table
A, below.
Table A (Required Signatures Per District)
Congressional
District
Gubernatorial
Votes Cast in
2024
5% for
Statutory
Change
8% for
Constitutional
Change
1st
2nd
3rd
4th
5th
6th
7th
8th
311,915
431,395
401,227
370,875
333,988
378,080
371,969
360,817
15,596
21,570
20,062
18,544
16,700
18,904
18,599
18,041
24,954
34,512
32,099
29,670
26,720
30,247
29,758
28,866
For example, the number of signatures required for six of the eight
congressional districts with the lowest number of votes for governor at the
last general election are shown in Table B on page 6.
Table B (Example for Minimum Number of Signatures Required)
Congressional
District
Example
Statutory
Change
Example
Constitutional
Change
1st
4th
5th
6th
7th
8th
15,596
18,544
16,700
18,904
18,599
18,041
24,954
29,670
26,720
30,247
29,758
28,866
MINIMUM
SIGNATURES
REQUIRED
106,384
170,215
5
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
680a
SC101805 Appeal Document Number 33 Page 8
Filing Instructions and Procedures
1. Petitioners must submit all petition pages at the same time to the
secretary of state’s office by 5:00 PM on May 3, 2026 for the 2026 election
cycle.
2. Petitioners must submit an Initiative Petition Receipt form with each
petition showing the number of pages by county that are being filed with the
secretary of state’s office. This form is available from the Elections Division
(800-669-8683 or 573-751-2301) and will become the petitioner’s receipt
after review by the secretary of state’s office.
3. Petitioners must number petition pages sequentially and by county
before submitting the petition to the secretary of state’s office. The page
number and county in which the petition signers on that page are registered
to vote must be designated in the upper right-hand corner of each page. (i.e.,
Cole 1, Cole 2, etc.) The county in which the petition signers are registered
to vote must also be designated in the paragraph at the top of the page which
begins with “We, the undersigned” and in the blank immediately before the
circulator’s signature at the bottom of the page. The “Circulator’s Affidavit”
at the bottom of the page must also state the county in which the circulator’s
signature is notarized.
4. When attaching the full and correct text of the proposed measure to
each page of an initiative petition, we recommend the following guidelines:
• If space allows, place the full text of the proposed measure on the
back of each petition signature page.
• If the full text of the proposed measure exceeds the space on the back
of each page, the additional text may be attached on the front and back of
each consecutive page and stapled in a consistent location. Remember that
all petitions must be circulated and submitted in the form of the sample sheet
that was approved by the secretary of state’s office.
5. Petitioners should arrange petition pages in file folders limited to 100
pages per folder, which should be labeled with county and page numbers.
(i.e., Cole County 1–100, Cole County 101–200, etc.)
6. Petitioners should place the folders in cardboard file boxes clearly
labeled with the contents, by county.
7. Please ensure that the name and address of each petition circulator is
clearly printed on the circulator affidavit on each petition page. The secretary
of state’s office will not count any signatures on petition pages circulated
by an individual who has not registered with the secretary of state on or
before 5:00 PM on the final day for filing petitions. A petition circulator is
considered registered at the time a signed circulator’s affidavit is delivered
to the secretary of state’s office.
6
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
681a
SC101805 Appeal Document Number 33 Page 9
8. Each petition circulator must be at least 18 years old and registered
with the secretary of state. No person shall qualify as a circulator who has
been convicted of, found guilty of, or pled guilty to an offense involving
forgery under the laws of this state or an offense under the laws of any other
jurisdiction if that offense would be considered forgery under the laws of
this state.
7
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
682a
SC101805 Appeal Document Number 33 Page 10
Missouri Congressional Districts
District
1
County
Population
St. Louis City, St. Louis (part).
748,616
2
Franklin, St. Charles (part), St. Louis (part),
Warren (part).
748,616
3
Boone (part), Callaway, Camden (part), Cole,
Cooper, Crawford, Gasconade, Jefferson (part),
Maries, Miller, Moniteau, Montgomery, Osage,
St. Charles (part), Warren (part), Washington.
748,615
4
Barton, Bates, Benton, Boone (part), Camden (part),
Cass, Cedar, Dade, Dallas, Henry, Hickory,
Howard, Jackson (part), Johnson, Laclede,
Lafayette, Morgan, Pettis, Polk, Pulaski, Saline,
St. Clair, Vernon, Webster (part).
748,616
Clay (part), Jackson (part), Kansas City.
748,616
6
Adair, Andrew, Atchison, Audrain, Buchanan,
Caldwell, Carroll, Chariton, Clark, Clay (part),
Clinton, Daviess, DeKalb, Gentry, Grundy,
Harrison, Holt, Jackson (part), Knox, Lewis,
Lincoln, Linn, Livingston, Macon, Marion, Mercer,
Monroe, Nodaway, Pike, Platte, Putnam, Ralls,
Randolph, Ray, Schuyler, Scotland, Shelby,
Sullivan, Worth.
748,616
7
Barry, Christian, Greene, Jasper, Lawrence,
McDonald, Newton, Polk, Stone, Taney,
Webster (part).
748,616
8
Bollinger, Butler, Cape Girardeau, Carter,
Dent, Douglas, Dunklin, Howell, Iron,
Jefferson (part), Madison, Mississippi,
New Madrid, Oregon, Ozark, Pemiscot, Perry,
Phelps, Reynolds, Ripley, St. Francois,
Ste. Genevieve, Scott, Shannon, Stoddard, Texas,
Wayne, Wright.
748,616
5
8
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
683a
SC101805 Appeal Document Number 33 Page 11
Congressional District Map
This map shows the current boundaries of the congressional districts
as they were apportioned according to House Bill 2909, 101st General
Assembly, 2nd Regular Session in 2022.
Detailed congressional maps for split jurisdictions may be obtained from
the University of Missouri Geographic Resources Center. To order, call (573)
882-1404.
General Maps of Congressional Districts can be found at the secretary of
state’s website: www.sos.mo.gov/elections
Redistricting questions can be directed to the State Demographer, Office
of Administration, Division of Budget and Planning, (573) 751-2345.
9
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
684a
SC101805 Appeal Document Number 33 Page 12
Sample Initiative Petition Submission Cover Page
INITIATIVE PETITION
SUBMISSION COVER
PAGE
RETURN TO:
Missouri Secretary of State
Elections Division
600 W. Main St.
Jefferson City, MO 65101
MISSOURI SECRETARY OF STATE
DENNY HOSKINS, CPA
PHONE: (800) 669-8683
WEB: http://www.sos.mo.gov
Pursuant to Sections 116.100 and 116.332, RSMo, upon submitting a petition,
please provide the following contact information:
DATE OF SUBMISSION
LAST NAME*
FIRST NAME*
STREET ADDRESS*
CITY*
STATE*
PHONE*
EMAIL
ZIP CODE*
ORGANIZATION
CHECK ONE*:
A PERSON OR COMMITTEE, OTHER THAN ME, IS FUNDING A PORTION OF THE DRAFTING OR SUBMISSION
OF THIS SAMPLE SHEET. AS A RESULT, I AM ATTACHING A COPY OF THE FILED STATEMENT OF COMMITTEE
ORGANIZATION REQUIRED UNDER SECTION 130.021.5, RSMO, SHOWING THE DATE THE STATEMENT WAS
FILED.
I AFFIRM THAT NO PORTION OF THE DRAFTING OR SUBMISSION OF THIS SAMPLE SHEET HAS BEEN FUNDED
BY A PERSON OR COMMITTEE OTHER THAN ME.
SIGNATURE OF PERSON SUBMITTING THE SAMPLE SHEET*
*REQUIRED INFORMATION
To request submission cover pages, please visit our website at www.sos.
mo.gov/elections/petitions or contact the Elections Division at (800) 6698683 or (573) 751-2301.
10
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
685a
SC101805 Appeal Document Number 33 Page 13
Constitution of Missouri
Article III, Sections 49-53
INITIATIVE AND REFERENDUM
Section 49. Reservation of power to enact and reject laws.—The people
reserve power to propose and enact or reject laws and amendments to the
constitution by the initiative, independent of the general assembly, and also
reserve power to approve or reject by referendum any act of the general
assembly, except as hereinafter provided.
Section 50. Initiative petitions—signatures required—form and
procedure.—Initiative petitions proposing amendments to the constitution
shall be signed by eight percent of the legal voters in each of two-thirds of
the congressional districts in the state, and petitions proposing laws shall be
signed by five percent of such voters. Every such petition shall be filed with the
secretary of state not less than six months before the election and shall contain
an enacting clause and the full text of the measure. Petitions for constitutional
amendments shall not contain more than one amended and revised article of
this constitution, or one new article which shall not contain more than one
subject and matters properly connected therewith, and the enacting clause
thereof shall be “Be it resolved by the people of the state of Missouri that the
Constitution be amended:”. Petitions for laws shall contain not more than one
subject which shall be expressed clearly in the title, and the enacting clause
thereof shall be “Be it enacted by the people of the state of Missouri:”.
Section 51. Appropriations by initiative—effective date of initiated
laws—conflicting laws concurrently adopted.—The initiative shall not be
used for the appropriation of money other than of new revenues created and
provided for thereby, or for any other purpose prohibited by this constitution.
Except as provided in this constitution, any measure proposed shall take effect
when approved by a majority of the votes cast thereon. When conflicting
measures are approved at the same election the one receiving the largest
affirmative votes shall prevail.
Section 52(a). Referendum—exceptions—procedure.—A referendum
may be ordered (except as to 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) either by petitions signed
by five percent of the legal voters in each of two-thirds of the congressional
districts in the state, or by the general assembly, as other bills are enacted.
Referendum petitions shall be filed with the secretary of state not more than
ninety days after the final adjournment of the session of the general assembly
which passed the bill on which the referendum is demanded.
11
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
686a
SC101805 Appeal Document Number 33 Page 14
Section 52(b). Veto power—elections—effective date.—The veto power
of the governor shall not extend to measures referred to the people. 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. Any measure
referred to the people shall take effect when approved by a majority of the votes
cast thereon, and not otherwise. This section shall not be construed to deprive
any member of the general assembly of the right to introduce any measure.
Section 53. Basis for computation of signatures required.—The total
vote for governor at the general election last preceding the filing of any
initiative or referendum petition shall be used to determine the number of
legal voters necessary to sign the petition. In submitting the same to the
people the secretary of state and all other officers shall be governed by
general laws.
Article XII, Section 2(b)
AMENDING THE CONSTITUTION
Section 2(b). Submission of amendments proposed by general assembly
or by the initiative.—All amendments proposed by the general assembly
or by the initiative shall be submitted to the electors for their approval or
rejection by official ballot title as may be provided by law, on a separate
ballot without party designation, at the next general election, or at a special
election called by the governor prior thereto, at which he may submit any of
the amendments. No such proposed amendment shall contain more than one
amended and revised article of this constitution, or one new article which
shall not contain more than one subject and matters properly connected
therewith. If possible, each proposed amendment shall be published once a
week for two consecutive weeks in two newspapers of different political faith
in each county, the last publication to be not more than thirty nor less than
fifteen days next preceding the election. If there be but one newspaper in any
county, publication for four consecutive weeks shall be made. If a majority of
the votes cast thereon is in favor of any amendment, the same shall take effect
at the end of thirty days after the election. More than one amendment at the
same election shall be so submitted as to enable the electors to vote on each
amendment separately.
12
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
687a
SC101805 Appeal Document Number 33 Page 15
Revised Statutes of Missouri,
Chapter 116
INITIATIVE AND REFERENDUM
116.010. Definitions.—As used in this chapter, unless the context
otherwise indicates,
(1) “County” means any one of the several counties of this state or the
city of St. Louis;
(2) “Election authority” means a county clerk or board of election
commissioners, as established by section 115.015, RSMo;
(3) “General election” means the first Tuesday after the first Monday in
November in even-numbered years;
(4) “Official ballot title” means the summary statement and fiscal note
summary prepared for all statewide ballot measures in accordance with the
provisions of this chapter which shall be placed on the ballot and, when
applicable, shall be the petition title for initiative or referendum petitions;
(5) “Statewide ballot measure” means a constitutional amendment
submitted by initiative petition, the general assembly or a constitutional
convention, a statutory measure submitted by initiative or referendum
petition, the question of holding a constitutional convention, and a
constitution proposed by a constitutional convention;
(6) “Voter” means a person registered to vote in accordance with section
115.151, RSMo.
(L. 1980 S.B. 658, A.L. 1997 S.B. 132)
116.020. Application of laws.—This chapter shall apply to elections on
statewide ballot measures. The election procedures contained in chapter
115, RSMo, shall apply to elections on statewide ballot measures, except
to the extent that the provisions of chapter 116 directly conflict, in which
case chapter 116 shall prevail, and except to the extent that a constitutional
convention’s provisions under section 3(c) of article XII of the constitution
directly conflict, in which case the convention’s provisions shall prevail.
(L. 1980 S.B. 658) Effective 1-1-81
116.025. Attorney general sent fair ballot language, when—statement
posted at polling place.—The secretary of state within twenty days of
receiving a statewide ballot measure shall prepare and transmit to the
attorney general fair ballot language statements that fairly and accurately
explain what a vote for and what a vote against the measure represent. Each
statement shall be posted in each polling place next to the sample ballot.
Such fair ballot language statements shall be true and impartial statements
13
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
688a
SC101805 Appeal Document Number 33 Page 16
of the effect of a vote for and against the measure in language neither
intentionally argumentative nor likely to create prejudice for or against the
proposed measure. In addition, such fair ballot language shall include a
statement as to whether the measure will increase, decrease, or have no
impact on taxes, including the specific category of tax. Such fair ballot
language statements may be challenged in accordance with section 116.190.
The attorney general shall within ten days approve the legal content and
form of the proposed statements.
(L. 2003 H.B. 511)
*116.030. Referendum petition, form—clerical and technical errors
to be disregarded, penalties for false signature.—The following shall be
substantially the form of each page of referendum petitions on any law
passed by the general assembly of the state of Missouri:
County ......................
Page No. ....................
It is a class A misdemeanor punishable, notwithstanding the provisions of
section 560.021, RSMo, to the contrary, for a term of imprisonment not
to exceed one year in the county jail or a fine not to exceed ten thousand
dollars or both, for anyone to sign any referendum petition with any name
other than his or her own, or knowingly to sign his or her name more than
once for the same measure for the same election, or to sign a petition when
such person knows he or she is not a registered voter.
PETITION FOR REFERENDUM
To the Honorable .........., Secretary of State for the state of Missouri:
We, the undersigned, registered voters of the state of Missouri and .............
County (or city of St. Louis), respectfully order that the Senate (or House)
Bill No. .... entitled (title of law), passed by the .......... general assembly of
the state of Missouri, at the ............. regular (or special) session of the .........
general assembly, shall be referred to the voters of the state of Missouri, for
their approval or rejection, at the general election to be held on the ....... day
of .........., ....., unless the general assembly shall designate another date, and
each for himself or herself says: I have personally signed this petition; I am
a registered voter of the state of Missouri and .......... County (or city of St.
Louis); my registered voting address and the name of the city, town or village
in which I live are correctly written after my name.
14
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
689a
SC101805 Appeal Document Number 33 Page 17
(Official Ballot title) ....................
CIRCULATOR’S AFFIDAVIT
State Of Missouri
County Of ....................
I, ......................., being first duly sworn, say (print or type names of signers)
NAME
DATE
(Signature)
SIGNED
REGISTERED
VOTING
ZIP
CONGR.
ADDRESS
CODE
DIST.
(Street) (City,
Town or Village)
NAME
(Printed
or Typed)
(Here follow numbered lines for signers)
signed this page of the foregoing petition, and each of them signed his or
her name thereto in my presence; I believe that each has stated his or her
name, registered voting address and city, town or village correctly, and that
each signer is a registered voter of the state of Missouri and .......... County.
FURTHERMORE, I HEREBY SWEAR OR AFFIRM UNDER PENALTY OF
PERJURY THAT ALL STATEMENTS MADE BY ME ARE TRUE AND CORRECT
AND THAT I HAVE NEVER BEEN CONVICTED OF, FOUND GUILTY OF,
OR PLED GUILTY TO ANY OFFENSE INVOLVING FORGERY.
I am at least 18 years of age. I do .... do not .... (check one) expect to be paid
for circulating this petition. If paid, list the payer ..........
..............................................................
Signature of Affiant
(Person obtaining signatures)
..............................................................
(Printed Name of Affiant)
..............................................................
Address of Affiant
Subscribed and sworn to before me this ....... day of ......., A.D. ........
.............................................................
Signature of Notary
.............................................................
Address of Notary
Notary Public (Seal)
My commission expires ................................
15
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
690a
SC101805 Appeal Document Number 33 Page 18
If this form is followed substantially and the requirements of section 116.050
and section 116.080 are met, it shall be sufficient, disregarding clerical and
merely technical errors.
(L. 1980 S.B. 658, A.L. 1986 H.B. 1471, et al., A.L. 1997 S.B. 132, A.L. 1999 H.B. 676, A.L.
2013 H.B. 117) *Effective 11-04-14
*Revisor’s Note: Section 560.021, as referenced in the form contained in this section, was
repealed by S.B. 491, 2014, effective 1-01-17.
*116.040. Initiative petition for law or constitutional amendment,
form—clerical and technical errors to be disregarded, penalties for false
signature.—The following shall be substantially the form of each page of
each petition for any law or amendment to the Constitution of the state of
Missouri proposed by the initiative:
County ............................
Page No. ..........................
It is a class A misdemeanor punishable, notwithstanding the provisions of
section 560.021, RSMo, to the contrary, for a term of imprisonment not
to exceed one year in the county jail or a fine not to exceed ten thousand
dollars or both, for anyone to sign any initiative petition with any name other
than his or her own, or knowingly to sign his or her name more than once
for the same measure for the same election, or to sign a petition when such
person knows he or she is not a registered voter.
INITIATIVE PETITION
To the Honorable .........., Secretary of State for the state of Missouri:
We, the undersigned, registered voters of the state of Missouri and ..........
County (or city of St. Louis), respectfully order that the following proposed
law (or amendment to the constitution) shall be submitted to the voters of
the state of Missouri, for their approval or rejection, at the general election to
be held on the ...... day of .........., ....., and each for himself or herself says:
I have personally signed this petition, I am a registered voter of the state
of Missouri and .......... County (or city of St. Louis), my registered voting
address and the name of the city, town or village in which I live are correctly
written after my name.
16
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
691a
SC101805 Appeal Document Number 33 Page 19
(Official Ballot title) ....................
CIRCULATOR’S AFFIDAVIT
STATE OF MISSOURI
COUNTY OF ............
I, ......................., being first duly sworn, say (print or type names of signers)
NAME
DATE
(Signature)
SIGNED
REGISTERED
VOTING
ZIP
CONGR.
ADDRESS
CODE
DIST.
(Street) (City,
Town or Village)
NAME
(Printed
or Typed)
(Here follow numbered lines for signers)
signed this page of the foregoing petition, and each of them signed his or her
name thereto in my presence, I believe that each has stated his or her name,
registered voting address and city, town or village correctly, and that each
signer is a registered voter of the state of Missouri and ...................... County.
FURTHERMORE, I HEREBY SWEAR OR AFFIRM UNDER PENALTY OF
PERJURY THAT ALL STATEMENTS MADE BY ME ARE TRUE AND CORRECT
AND THAT I HAVE NEVER BEEN CONVICTED OF, FOUND GUILTY OF,
OR PLED GUILTY TO ANY OFFENSE INVOLVING FORGERY.
I am at least 18 years of age. I do .... do not .... (check one) expect to be paid
for circulating this petition. If paid, list the payer ..........
..............................................................
Signature of Affiant
(Person obtaining signatures)
..............................................................
(Printed Name of Affiant)
..............................................................
Address of Affiant
Subscribed and sworn to before me this ....... day of ......., A.D. ........
.............................................................
Signature of Notary
.............................................................
Address of Notary
Notary Public (Seal)
My commission expires ................................
17
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
692a
SC101805 Appeal Document Number 33 Page 20
If this form is followed substantially and the requirements of section 116.050
and section 116.080 are met, it shall be sufficient, disregarding clerical and
merely technical errors.
(L. 1980 S.B. 658, A.L. 1986 H.B. 1471, et al., A.L. 1997 S.B. 132, A.L. 1999 H.B. 676, A.L.
2013 H.B. 117) *Effective 11-04-14
*Revisor’s Note: Section 560.021, as referenced in the form contained in this section, was
repealed by S.B. 491, 2014, effective 1-01-17.
116.050. Initiative and referendum petitions, requirements.—1.
Initiative and referendum petitions filed under the provisions of this chapter
shall consist of pages of a uniform size. Each page, excluding the text of the
measure, shall be no larger than eight and one-half by fourteen inches. Each
page of an initiative petition shall be attached to or shall contain a full and
correct text of the proposed measure. Each page of a referendum petition
shall be attached to or shall contain a full and correct text of the measure on
which the referendum is sought.
2. The full and correct text of all initiative and referendum petition
measures shall:
(1) Contain all matter which is to be deleted included in its proper place
enclosed in brackets and all new matter shown underlined;
(2) Include all sections of existing law or of the constitution which would
be repealed by the measure; and
(3) Otherwise conform to the provisions of article III, section 28 and
article III, section 50 of the constitution and those of this chapter.
(L. 1980 S.B. 658, A.L. 1997 S.B. 132)
116.060. Initiative and referendum petitions, who may sign—residents
of one county only on a designated page.—Any registered voter of the state
of Missouri may sign initiative and referendum petitions. However, each
page of an initiative or referendum petition shall contain signatures of voters
from only one county. Each petition page filed with the secretary of state
shall have the county where the signers are registered designated in the
upper right-hand corner of such page. Signatures of voters from counties
other than the one designated by the circulator in the upper right-hand
corner on a given page shall not be counted as valid.
(L. 1980 S.B. 658, A.L. 1999 H.B. 676) Effective 6-16-99
116.070. Petitioner may sign by mark, procedure.—When any voter
wishes to sign an initiative or referendum petition and is unable to sign his
name, the circulator shall print the required information on the petition.
The voter shall then make his mark, and the circulator shall attest to it by
his signature. For purposes of this chapter, all marks made and attested in
accordance with this section shall be considered signatures.
(L. 1980 S.B. 658) Effective 1-1-81
18
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
693a
SC101805 Appeal Document Number 33 Page 21
116.080. Qualifications of circulator—affidavit, notarization,
penalty.—1. Each petition circulator shall be at least eighteen years of
age and registered with the secretary of state. Signatures collected by any
circulator who has not registered with the secretary of state pursuant to this
chapter on or before 5:00 p.m. on the final day for filing petitions with the
secretary of state shall not be counted. A petition circulator shall be deemed
registered at the time such circulator delivers a signed circulator’s affidavit
pursuant to section 116.030, with respect to a referendum petition, or section
116.040, with respect to an initiative petition, to the office of the secretary of
state. No person shall qualify as a petition circulator who has been convicted
of, found guilty of, or pled guilty to an offense involving forgery under the
laws of this state or an offense under the laws of any other jurisdiction if that
offense would be considered forgery under the laws of this state.
2. Each petition circulator shall subscribe and swear to the proper
affidavit on each petition page such circulator submits before a notary public
commissioned in Missouri. When notarizing a circulator’s signature, a notary
public shall sign his or her official signature and affix his or her official seal
to the affidavit only if the circulator personally appears before the notary and
subscribes and swears to the affidavit in his or her presence.
3. Any circulator who falsely swears to a circulator’s affidavit knowing it
to be false is guilty of a class A misdemeanor punishable, notwithstanding the
provisions of section 560.021* to the contrary, for a term of imprisonment
not to exceed one year in the county jail or a fine not to exceed ten thousand
dollars or both.
(L. 1980 S.B. 658, A.L. 1999 H.B. 676, A.L. 2013 H.B. 117) *Effective 11-04-14
*Section 560.021 was repealed by S.B. 491, 2014, effective 1-01-17.
116.090. Petition signature fraud, penalty.—1. Any person who commits
any of the following actions, is guilty of the crime of petition signature fraud:
(1) Signs any name other than his or her own to any petition, or who
knowingly signs his or her name more than once for the same measure for
the same election, or who knows he or she is not at the time of signing or
circulating the same a Missouri registered voter and a resident of this state; or
(2) Intentionally submits petition signature sheets with the knowledge
that the person whose name appears on the signature sheet did not actually
sign the petition; or
(3) Causes a voter to sign a petition other than the one the voter intended
to sign; or
(4) Forges or falsifies signatures; or
(5) Knowingly accepts or offers money or anything of value to another
person in exchange for a signature on a petition.
19
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
694a
SC101805 Appeal Document Number 33 Page 22
2. Any person who knowingly causes a petition circulator’s signatures
to be submitted for counting, and who either knows that such circulator
has violated subsection 1 of this section or, after receiving notice of facts
indicating that such person may have violated subsection 1 of this section,
causes the signatures to be submitted with reckless indifference as to whether
such circulator has complied with subsection 1 of this section, shall also be
deemed to have committed the crime of petition signature fraud.
3. A person who violates subsection 1 or 2 of this section, shall,
upon conviction thereof, be guilty of a class A misdemeanor punishable,
notwithstanding the provisions of section 560.021* to the contrary, by a term
of imprisonment not to exceed one year in the county jail or a fine not to
exceed ten thousand dollars or both.
4. Any person employed by or serving as an election authority, that has
reasonable cause to suspect a person has committed petition signature fraud,
shall immediately report or cause a report to be made to the appropriate
prosecuting authorities. Failure to so report or cause a report to be made
shall be a class A misdemeanor.
(L. 1980 S.B. 658, A.L. 1999 H.B. 676, A.L. 2013 H.B. 117)
*Section 560.021 was repealed by S.B. 491, 2014, effective 1-01-17.
116.100. Filing of petition, procedure.—The secretary of state shall
not accept any referendum petition submitted later than 5:00 p.m. on the
final day for filing referendum petitions. The secretary of state shall not
accept any initiative petition submitted later than 5:00 p.m. on the final
day for filing initiative petitions. All pages shall be submitted at one time.
When an initiative or referendum petition is submitted to the secretary of
state, the signature pages shall be in order and numbered sequentially by
county, except in counties that include multiple congressional districts, the
signatures may be ordered and numbered using an alternate numbering
scheme approved in writing by the secretary of state prior to submission
of the petition. Any petition that is not submitted in accordance with this
section, disregarding clerical and merely technical errors, shall be rejected
as insufficient. After verifying the count of signature pages, the secretary of
state shall issue a receipt indicating the number of pages presented from
each county. When a person submits a petition he or she shall designate to
the secretary of state the name and the address of the person to whom any
notices shall be sent under sections 116.140 and 116.180.
(L. 1980 S.B. 658, A.L. 1983 S.B. 234, A.L. 1997 S.B. 132, A.L. 1999 H.B. 676) Effective 6-16-99
116.110. Signature may be withdrawn, when, how, effect, penalty.—
Any voter who has signed an initiative or referendum petition may withdraw
his or her signature from that petition by submitting to the secretary of state,
before the petition is filed with the secretary of state, a sworn statement
requesting that his or her signature be withdrawn and affirming the name of
20
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
695a
SC101805 Appeal Document Number 33 Page 23
the petition signed, the name the voter used when signing the petition, the
address of the voter and the county of residence. It is a class A misdemeanor
punishable, notwithstanding the provisions of section 560.021, RSMo, to the
contrary, for a term of imprisonment not to exceed one year in the county
jail or a fine not to exceed ten thousand dollars or both, to knowingly file a
false withdrawal statement with the secretary of state.
(L. 1980 S.B. 658, A.L. 1999 H.B. 676) Effective 6-16-99
*Section 560.021 was repealed by S.B. 491, 2014, effective 1-01-17.
116.115. Withdrawal of petition, when—vacation of official ballot
title, when.—Any person who submits a sample sheet to or files an initiative
petition with the secretary of state may withdraw the petition upon written
notice to the secretary of state. If such notice is submitted to the secretary
of state, the proposed petition shall no longer be circulated by any person,
committee, or other entity. The secretary of state shall vacate the certification
of the official ballot title within three days of receiving notice of the
withdrawal.
(L. 2013 H.B. 117) Effective 11-04-14
116.120. Secretary of state to determine sufficiency of form and
compliance—invalid signatures not counted—signatures may be verified
by random sampling, procedure and requirements.—1. When an initiative
or referendum petition is submitted to the secretary of state, he or she shall
examine the petition to determine whether it complies with the Constitution
of Missouri and with this chapter. Signatures on petition pages that have been
collected by any person who is not properly registered with the secretary of
state as a circulator shall not be counted as valid. Signatures on petition
pages that do not have the official ballot title affixed to the page shall not
be counted as valid. The secretary of state may verify the signatures on the
petition by use of random sampling. The random sample of signatures to
be verified shall be drawn in such a manner that every signature properly
filed with the secretary of state shall be given an equal opportunity to be
included in the sample. The process for establishing the random sample
and determining the statistically valid result shall be established by the
secretary of state. Such a random sampling shall include an examination of
five percent of the signatures.
2. If the random sample verification establishes that the number of
valid signatures is less than ninety percent of the number of qualified voters
needed to find the petition sufficient in a congressional district, the petition
shall be deemed to have failed to qualify in that district. In finding a petition
insufficient, the secretary of state does not need to verify all congressional
districts on each petition submitted if verification of only one or more districts
establishes the petition as insufficient.
21
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
696a
SC101805 Appeal Document Number 33 Page 24
3. If the random sample verification establishes that the number of
valid signatures total more than one hundred ten percent of the number
of qualified voters needed to find the petition sufficient in a congressional
district, the petition shall be deemed to qualify in that district.
4. If the random sampling shows the number of valid signatures within
a congressional district is within ninety to one hundred ten percent of the
number of signatures of qualified voters needed to declare the petition
sufficient in that district, the secretary of state shall order the examination
and verification of each signature filed.
(L. 1980 S.B. 658, A.L. 1988 S.B. 647, A.L. 1999 H.B. 676) Effective 6-16-99
116.130. Election authorities may be requested to verify signatures
either by random sampling or checking signatures, when, how.—1. The
secretary of state may send copies of petition pages to election authorities
to verify that the persons whose names are listed as signers to the petition
are registered voters. Such verification may either be of each signature or
by random sampling as provided in section 116.120, as the secretary shall
direct. If copies of the petition pages are sent to an election authority for
verification, such copies shall be sent pursuant to the following schedule:
(1) Copies of all pages from not less than one petition shall be received
in the office of the election authority not later than two weeks after the
petition is filed in the office of secretary of state;
(2) Copies of all pages of a total of three petitions shall be received in the
office of the election authority not later than three weeks after the petition is
filed in the office of the secretary of state;
(3) If more than three petitions are filed, all copies of petition pages,
including those petitions selected for verification by random sample pursuant
to section 116.120, shall be received in the office of the election authority
not later than the fourth week after the petition is filed in the office of the
secretary of state.
Each election authority shall check the signatures against voter
registration records in the election authority’s jurisdiction, but the election
authority shall count as valid only the signatures of persons registered as
voters in the county named in the circulator’s affidavit. Signatures shall not
be counted as valid if they have been struck through or crossed out.
2. If the election authority is requested to verify the petition by random
sampling, such verification shall be completed and certified not later than
thirty days from the date that the election authority receives the petition from
the secretary of state. If the election authority is to verify each signature, such
verification must be completed, certified and delivered to the secretary of
state by 5:00 p.m. on the last Tuesday in July prior to the election, or in the
event of complete verification of signatures after a failed random sample, full
verification shall be completed, certified and delivered to the secretary of
22
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
697a
SC101805 Appeal Document Number 33 Page 25
state by 5:00 p.m. on the last Tuesday in July or by 5:00 p.m. on the Friday
of the fifth week after receipt of the signatures by the local election authority,
whichever is later.
3. If the election authority or the secretary of state determines that the
congressional district number written after the signature of any voter is not the
congressional district of which the voter is a resident, the election authority
or the secretary of state shall correct the congressional district number on
the petition page. Failure of a voter to give the voter’s correct congressional
district number shall not by itself be grounds for not counting the voter’s
signature.
4. The election authority shall return the copies of the petition pages to
the secretary of state with annotations regarding any invalid or questionable
signatures which the election authority has been asked to check by the
secretary of state. The election authority shall verify the number of pages
received for that county, and also certify the total number of valid signatures
of voters from each congressional district which the election authority has
been asked to check by the secretary of state.
5. The secretary of state is authorized to adopt rules to ensure uniform,
complete, and accurate checking of petition signatures either by actual count
or random sampling. No rule or portion of a rule promulgated pursuant to
this section shall become effective unless it has been promulgated pursuant
to the provisions of chapter 536, RSMo.
6. After a period of three years from the time of submission of the petitions
to the secretary of state, the secretary of state, if the secretary determines that
retention of such petitions is no longer necessary, may destroy such petitions.
(L. 1980 S.B. 658, A.L. 1988 S.B. 647, A.L. 1995 S.B. 3, A.L. 1997 S.B. 132, A.L. 1999 H.B.
676, A.L. 2003 S.B. 50)
116.140. Secretary of state’s authority not to count forged or fraudulent
signatures.—Notwithstanding certifications from election authorities under
section 116.130, the secretary of state shall have authority not to count
signatures on initiative or referendum petitions which are, in his opinion,
forged or fraudulent signatures.
(L. 1980 S.B. 658, A.L. 1988 S.B. 647) Effective 6-6-88
116.150. Secretary of state to issue certificate of sufficiency of petition,
when—if insufficient, certificate to state reasons.—1. After the secretary
of state makes a determination on the sufficiency of the petition and if
the 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.
2. The secretary of state shall issue a certificate only for a petition
approved pursuant to section 116.332. If the secretary of state finds the
23
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
698a
SC101805 Appeal Document Number 33 Page 26
petition insufficient, the secretary of state shall issue a certificate stating the
reason for the insufficiency.
3. 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.
(L. 1980 S.B. 658, A.L. 1985 H.B. 543, A.L. 1988 S.B. 647, A.L. 1999 H.B. 676) Effective 6-1699
116.153. Hearing to take public comments—joint committee on
legislative research to provide summary to secretary of state, posting on
website.—Within thirty days of issuing certification that the petition contains
a sufficient number of valid signatures pursuant to section 116.150, the joint
committee on legislative research shall hold a public hearing in Jefferson City
to take public comments concerning the proposed measure. Such hearing
shall be a public meeting under chapter 610. Within five business days after
the end of the public hearing, the joint committee on legislative research
shall provide a summary of the hearing to the secretary of state or his or her
designee and the secretary of state shall post a copy of the summary on the
website of the office of the secretary of state.
(L. 2013 H.B. 117) Effective 11-04-14
116.155. Official summaries and fiscal notes may be included in ballot
measures, summary to be official ballot title if included.—1. The general
assembly may include the official summary statement and a fiscal note
summary in any statewide ballot measure that it refers to the voters.
2. The official summary statement approved by the general assembly
shall, taken together with the approved fiscal note summary, be the official
ballot title and such summary statement shall contain no more than fifty
words, excluding articles. The title shall be a true and impartial statement
of the purposes of the proposed measure in language neither intentionally
argumentative nor likely to create prejudice either for or against the proposed
measure.
3. The fiscal note summary approved by the general assembly shall
contain no more than fifty words, excluding articles, which shall summarize
the fiscal note prepared for the measure in language neither argumentative
nor likely to create prejudice for or against the proposed measure.
(L. 1999 H.B. 676) Effective 6-16-99
116.160. Summary statement to be provided by the secretary of state
if summary not provided by general assembly—content.—1. If the general
assembly adopts a joint resolution proposing a constitutional amendment
or a bill without a fiscal note summary, which is to be referred to a vote of
24
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
699a
SC101805 Appeal Document Number 33 Page 27
the people, after receipt of such resolution or bill the secretary of state shall
promptly forward the resolution or bill to the state auditor. If the general
assembly adopts a joint resolution proposing a constitutional amendment
or a bill without an official summary statement, which is to be referred to
a vote of the people, within twenty days after receipt of the resolution or
bill, the secretary of state shall prepare and transmit to the attorney general
a summary statement of the measure as the proposed summary statement.
The secretary of state may seek the advice of the legislator who introduced
the constitutional amendment or bill and the speaker of the house or the
president pro tem of the legislative chamber that originated the measure. The
summary statement may be distinct from the legislative title of the proposed
constitutional amendment or bill. The attorney general shall within ten days
approve the legal content and form of the proposed statement.
2. The official summary statement shall contain no more than fifty
words, excluding articles. The title shall be a true and impartial statement
of the purposes of the proposed measure in language neither intentionally
argumentative nor likely to create prejudice either for or against the proposed
measure.
(L. 1980 S.B. 658, A.L. 1983 S.B. 234, A.L. 1985 H.B. 543, A.L. 1997 S.B. 132, A.L. 1999 H.B.
676) Effective 6-16-99
(2004) Secretary of State’s duty to place matters on a ballot are not finally triggered until receipt
of the original document. Nixon v. Blunt, 135 S.W.3d 416 (Mo. banc).
116.170. Fiscal note and fiscal note summary to be provided by state
auditor if not provided by general assembly.—If the general assembly adopts
a joint resolution proposing a constitutional amendment or a bill without a
fiscal note summary, which is to be referred to a vote of the people, the state
auditor shall, within thirty days of delivery to the auditor, prepare and file
with the secretary of state a fiscal note and a fiscal note summary for the
proposed measure in accordance with the provisions of section 116.175.
(L. 1980 S.B. 658, A.L. 1983 S.B. 234, A.L. 1993 S.B. 350, A.L. 1997 S.B. 132, A.L. 1999 H.B.
676) Effective 6-16-99
(1994) Where statute requires that cost be addressed in a fiscal note summary only in cases
when a proposition has cost, fiscal note summary attached to initiative proposition was not
insufficient when it did not address cost, since proposition would not generate cost or savings.
Committee on Legislative Research v. Mitchell, 886 S.W.2d 662 (Mo. App. W.D.).
116.175. Fiscal impact of proposed measure—fiscal note, fiscal note
summary, requirements—return of fiscal note for revision, when.—1.
Except as provided in section 116.155, upon receipt from the secretary
of state’s office of any petition sample sheet, joint resolution or bill, the
auditor shall assess the fiscal impact of the proposed measure. The state
auditor may consult with the state departments, local government entities,
the general assembly and others with knowledge pertinent to the cost of the
proposal. Proponents or opponents of any proposed measure may submit to
25
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
700a
SC101805 Appeal Document Number 33 Page 28
the state auditor a proposed statement of fiscal impact estimating the cost of
the proposal in a manner consistent with the standards of the governmental
accounting standards board and section 23.140, provided that all such
proposals are received by the state auditor within ten days of his or her
receipt of the proposed measure from the secretary of state.
2. Within twenty days of receipt of a petition sample sheet, joint
resolution or bill from the secretary of state, the state auditor shall prepare a
fiscal note and a fiscal note summary for the proposed measure and forward
both to the attorney general.
3. The fiscal note and fiscal note summary shall state the measure’s
estimated cost or savings, if any, to state or local governmental entities. The
fiscal note summary shall contain no more than fifty words, excluding articles,
which shall summarize the fiscal note in language neither argumentative nor
likely to create prejudice either for or against the proposed measure.
4. The attorney general shall, within ten days of receipt of the fiscal note
and the fiscal note summary, approve the legal content and form of the fiscal
note summary prepared by the state auditor and shall forward notice of such
approval to the state auditor.
5. If the attorney general or the circuit court of Cole County determines
that the fiscal note or the fiscal note summary does* not satisfy the
requirements of this section, the fiscal note and the fiscal note summary shall
be returned to the auditor for revision. A fiscal note or fiscal note summary
that does not satisfy the requirements of this section also shall not satisfy the
requirements of section 116.180.
(L. 1997 S.B. 132, A.L. 1999 H.B. 676, A.L. 2003 H.B. 511 merged with S.B. 623)
*Word “do” appears in original rolls.
(2012) Section imposing a duty on the State Auditor to prepare fiscal notes and fiscal note
summaries for initiative petitions is constitutional. Brown v. Carnahan, 370 S.W.3d 637 (Mo.
banc).
116.180. Copies of ballot title, fiscal note and fiscal note summary to
designated persons, when—ballot title to be affixed to petition, when.—
Within three days after receiving the official summary statement the
approved fiscal note summary and the fiscal note relating to any statewide
ballot measure, the secretary of state shall certify the official ballot title in
separate paragraphs with the fiscal note summary immediately following the
summary statement of the measure and shall deliver a copy of the official
ballot title and the fiscal note to the speaker of the house or the president
pro tem of the legislative chamber that originated the measure or, in the case
of initiative or referendum petitions, to the person whose name and address
are designated under section 116.332. Persons circulating the petition shall
affix the official ballot title to each page of the petition prior to circulation
26
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
701a
SC101805 Appeal Document Number 33 Page 29
and signatures shall not be counted if the official ballot title is not affixed to
the page containing such signatures.
(L. 1980 S.B. 658, A.L. 1997 S.B. 132, A.L. 1999 H.B. 676) Effective 6-16-99
116.185. Identical ballot titles may be changed, how.—Before the ballot
is printed, if the title of a ballot issue is identical or substantially identical
to the title of another ballot issue that will appear on the same ballot, the
election authority shall promptly notify the officer or entity that certifies the
election of the identical or substantially identical title, and if such officer or
entity submits a new title to the election authority, the election authority may
change the title of the ballot issue prior to printing the official ballot.
(L. 1999 H.B. 676 § 1)
116.190. Ballot title may be challenged, procedure—who are parties
defendant—changes may be made by court—appeal to supreme court,
when.—1. Any citizen who wishes to challenge the official ballot title or the
fiscal note prepared for a proposed constitutional amendment submitted by
the general assembly, by initiative petition, or by constitutional convention,
or for a statutory initiative or referendum measure, may bring an action in
the circuit court of Cole County. The action must be brought within ten days
after the official ballot title is certified by the secretary of state in accordance
with the provisions of this chapter.
2. The secretary of state shall be named as a party defendant in any action
challenging the official ballot title prepared by the secretary of state. When
the action challenges the fiscal note or the fiscal note summary prepared by
the auditor, the state auditor shall also be named as a party defendant. The
president pro tem of the senate, the speaker of the house and the sponsor of
the measure and the secretary of state shall be the named party defendants
in any action challenging the official summary statement, fiscal note or fiscal
note summary prepared pursuant to section 116.155.
3. The petition shall state the reason or reasons why the summary
statement portion of the official ballot title is insufficient or unfair and shall
request a different summary statement portion of the official ballot title.
Alternatively, the petition shall state the reasons why the fiscal note or the
fiscal note summary portion of the official ballot title is insufficient or unfair
and shall request a different fiscal note or fiscal note summary portion of the
official ballot title.
4. The action shall be placed at the top of the civil docket. Insofar as the
action challenges the summary statement portion of the official ballot title,
the court shall consider the petition, hear arguments, and in its decision
certify the summary statement portion of the official ballot title to the
secretary of state. Insofar as the action challenges the fiscal note or the fiscal
note summary portion of the official ballot title, the court shall consider the
petition, hear arguments, and in its decision, either certify the fiscal note or
27
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
702a
SC101805 Appeal Document Number 33 Page 30
the fiscal note summary portion of the official ballot title to the secretary
of state or remand the fiscal note or the fiscal note summary to the auditor
for preparation of a new fiscal note or fiscal note summary pursuant to the
procedures set forth in section 116.175. Any party to the suit may appeal to
the supreme court within ten days after a circuit court decision. In making
the legal notice to election authorities under section 116.240, and for the
purposes of section 116.180, the secretary of state shall certify the language
which the court certifies to him.
5. Any action brought under this section that is not fully and finally
adjudicated within one hundred eighty days of filing, and more than fiftysix days prior to election in which the measure is to appear, including all
appeals, shall be extinguished, unless a court extends such period upon a
finding of good cause for such extension. Such good cause shall consist
only of court-related scheduling issues and shall not include requests for
continuance by the parties.
(L. 1980 S.B. 658, A.L. 1985 H.B. 543, A.L. 1993 S.B. 350, A.L. 1997 S.B. 132, A.L. 1999 H.B.
676, A.L. 2003 H.B. 511 merged with S.B. 623, A.L. 2013 H.B. 117, A.L. 2015 S.B. 104)
116.195. Costs of court-ordered ballot title change to be paid by the
state.—Whenever the reprinting of a statewide ballot measure is necessary
as a result of a court-ordered change to the ballot language for such measure,
the costs of such reprinting shall be paid by the state.
(L. 1999 H.B. 676 § 2)
116.200. Secretary of state’s decision as to sufficiency of petition may
be reversed, procedure—appeal.—1. After 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. The action must be
brought within ten days after the certification is made. All such suits shall be
advanced on the court docket and heard and decided by the court as quickly
as possible.
2. If the court decides the petition is sufficient, the secretary of state shall
certify it as sufficient and attach a copy of the judgment. If the court decides
the petition is insufficient, the court shall enjoin the secretary of state from
certifying the measure and all other officers from printing the measure on
the ballot.
3. Within ten days after a decision is rendered, any party may appeal it
to the supreme court.
(L. 1980 S.B. 658) Effective 1-1-81
116.210. Numbering of proposed constitutional amend–ments.—The
secretary of state shall number proposed constitutional amendments in the
order in which they are passed by the general assembly, or submitted by
initiative petition, or adopted by constitutional convention. He shall number
28
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
703a
SC101805 Appeal Document Number 33 Page 31
the first as “Constitutional Amendment No. 1” and so on consecutively. A
new series of numbers shall be started after each general election.
(L. 1980 S.B. 658) Effective 1-1-81
116.220. Labeling of initiative and referendum measures.—The
secretary of state shall label statutory initiative and referendum measures
alphabetically in the order in which they are submitted by petition or in the
order in which they are passed by the general assembly. The secretary of
state shall label the first as “Proposition A”, and so on consecutively through
the letter Z, and then begin labeling as “Proposition AA” and so on. A new
series of letters shall be started after each general election. In the event a
measure is labeled prior to, but not voted on at, the next succeeding general
election, the letter assigned to such measure shall not be reassigned until
after such measure has been voted on by the people.
(L. 1980 S.B. 658, A.L. 1999 H.B. 676) Effective 6-16-99
116.230. Sample ballots to be prepared, form.—1. The secretary of state
shall prepare sample ballots in the following form.
2. The top of the ballot shall read:
“OFFICIAL BALLOT
STATE OF MISSOURI”
3. When constitutional amendments are submitted, the first heading
shall read:
“CONSTITUTIONAL AMENDMENTS”
There shall follow the numbers assigned under section 116.210 the
official ballot titles prepared under section 116.160 or 116.334, and the fiscal
note summaries prepared under section 116.170. Constitutional amendments
proposed by the general assembly shall be designated as “Proposed by
the general assembly”. Constitutional amendments proposed by initiative
petition shall be designated “Proposed by initiative petition”. Constitutional
amendments proposed by constitutional convention shall be designated as
“Proposed by constitutional convention”.
4. When statutory measures are submitted, the next heading shall read:
“STATUTORY MEASURES”
There shall follow the letters assigned under section 116.220, the official
ballot titles prepared under section 116.160 or 116.334, and the fiscal note
summaries prepared under section 116.170. Statutory initiative measures
shall be designated “Proposed by initiative petition”. Referendum measures
shall be designated “Referendum ordered by petition”.
(L. 1980 S.B. 658, A.L. 1985 H.B. 543)
29
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
704a
SC101805 Appeal Document Number 33 Page 32
116.240. Certification to election authorities of notice to be published—
contents.—Not later than the tenth Tuesday prior to an election at which a
statewide ballot measure is to be voted on, the secretary of state shall send
each election authority a certified copy of the legal notice to be published.
The legal notice shall include the date and time of the election and a sample
ballot.
(L. 1980 S.B. 658, A.L. 1986 H.B. 1471, et al., A.L. 1997 S.B. 132)
116.250. Publication of legal notice.—On receiving a notice under
section 116.240, each election authority shall cause the legal notice to be
published in accordance with subsection 2 of section 115.127, RSMo.
(L. 1980 S.B. 658) Effective 1-1-81
116.260. Newspapers for publication of text of measures to be
designated—measures to be published, how.—The secretary of state
shall designate in what newspaper or newspapers in each county the text
of statewide ballot measures shall be published. If possible, each shall be
published once a week for two consecutive weeks in two newspapers of
different political faiths in each county, the last publication to be not more
than thirty or less than fifteen days next preceding the election. If there is
but one newspaper in any county, publication for four consecutive weeks
shall be made, the first publication to be not less than twenty-eight days next
preceding the election. If there are two or more newspapers in a county,
none of which is of different political faiths from another, the statewide ballot
measures shall be published once a week for two consecutive weeks in any
two newspapers in the county with the last publication not more than thirty
or less than fifteen days next preceding the election.
(L. 1980 S.B. 658, A.L. 1983 H.B. 670, A.L. 1997 S.B. 132)
116.270. Publications fund created—payments from fund for what, how
made.—1. There is hereby created a “Publications Fund” which shall be
used only to pay printing, publication, and other expenses incurred in
submitting statewide ballot measures to the voters.
2. The secretary of state shall certify to the commissioner of administration
all valid claims for payment from the publications fund. On receiving the
certified claims, the commissioner of administration shall issue warrants on
the state treasurer payable to each individual out of the publications fund.
(L. 1980 S.B. 658) Effective 1-1-81
116.280. Paper ballots for statewide measures, form.—In jurisdictions
using paper ballots, election authorities shall cause the ballots for statewide
ballot measures to be printed on paper not less than four inches wide and
ten inches long, and all in the same color and size. Measures may be printed
in more than one column.
(L. 1980 S.B. 658) Effective 1-1-81
30
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
705a
SC101805 Appeal Document Number 33 Page 33
116.290. Printing of copies of statewide measures—to be posted at
polling places—distribution, exception.—1. The secretary of state shall
distribute copies of each statewide ballot measure, except proposed
constitutions as published in newspapers for legal notice of the election.
2. The secretary of state shall print copies of each proposed constitution
in pamphlet form.
3. From copies delivered by the secretary of state, each election authority
shall post at least two copies of each notice and pamphlet at each polling
place during the time the polls are open.
4. The secretary of state shall print any new language being proposed for
adoption or rejection in boldface type.
(L. 1980 S.B. 658, A.L. 1983 S.B. 234)
116.300. Challengers and watchers at polling places, how designated.—
Not later than the fourth Tuesday prior to an election on a statewide ballot
measure, each chairman of a county campaign committee favoring a
measure and each chairman of a county campaign committee opposing a
measure shall file with the election authority a list of committee officers and a
request to have the right to designate challengers and watchers under section
116.310. If only one committee favoring a particular measure and one
committee opposing a particular measure file a list and a request, then each
filing chairman shall have the right to designate challengers and watchers
under section 116.310. If more than one committee favoring a particular
measure or more than one committee opposing a particular measure files a
list and request, then the election authority shall determine which chairman
has the right to designate challengers and watchers. If the measure was
submitted by initiative or referendum petition, the person designated under
section 116.100 as the person to receive notice under sections 116.140
and 116.180 shall be entitled to designate the county campaign committee
chairmen’s names to the proper election authorities by the fourth Tuesday
prior to the election on that measure.
(L. 1980 S.B. 658) Effective 1-1-81
116.310. Time limited for designating challengers and watchers for
polling places and counting locations—effect of failure to designate by
prescribed time.—1. Not later than the Tuesday prior to an election on a
statewide ballot measure, each county campaign committee chairman who
had the right to designate challengers under section 116.300 shall designate
such challengers, who may be present at each polling place during the
hours of voting. Each such chairman shall also by the same time designate
a challenger for each location at which absentee ballots are counted.
The challengers so designated may be present while the ballots are being
prepared for counting and being counted.
31
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
706a
SC101805 Appeal Document Number 33 Page 34
2. Not later than the Tuesday prior to an election on a statewide ballot
measure, each campaign committee chairman who has the right to designate
watchers under section 116.300 shall designate a watcher for each place
votes are counted.
3. After challengers and watchers have been designated, the provisions
contained in sections 115.105, 115.107, 115.109, and 115.111, RSMo, shall
apply to them.
4. Failure to designate challengers and watchers by the prescribed times
shall cause the county campaign committee to forfeit its right to name such
persons for those omitted locations for that election.
(L. 1980 S.B. 658) Effective 1-1-81
116.320. Adoption of measure, vote required—effect of approval of
conflicting measures.—1. Each statewide ballot measure receiving a majority
of affirmative votes is adopted.
2. If voters approve two or more conflicting statutes at the same election,
the statute receiving the largest affirmative vote shall prevail, even if that
statute did not receive the greatest majority of affirmative votes.
3. If voters approve two or more conflicting constitutional amendments
at the same election, the amendment receiving the largest affirmative vote
shall prevail, even if that amendment did not receive the greatest majority
of affirmative votes.
(L. 1980 S.B. 658) Effective 1-1-81
116.330. Board of canvassers or governor to issue state–ment.—1. After
an election at which any statewide ballot measure, other than a proposed
constitution or constitutional amendment submitted by a constitutional
convention, is voted upon, the secretary of state shall convene the board of
state canvassers to total the abstracts. Not later than two weeks after receiving
all required abstracts, the board shall issue a statement giving the number of
votes cast “yes” and “no” on each question. If voters approve two or more
measures at one election which are known to conflict with one another, or
to contain conflicting provisions, the board shall also state which received
the largest affirmative vote.
2. After an election at which a proposed constitution or constitutional
amendment adopted by a constitutional convention is submitted, the
governor shall proclaim the results in accordance with section 3(c), article
XII of the constitution.
(L. 1980 S.B. 658) Effective 1-1-81
116.332. Petitions for constitutional amendments, statutory initiative
or referendum, requirements, procedure.—1. Before a constitutional
amendment petition, a statutory initiative petition, or a referendum petition
32
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
707a
SC101805 Appeal Document Number 33 Page 35
may be circulated for signatures, a sample sheet must be submitted to the
secretary of state in the form in which it will be circulated. When a person
submits a sample sheet of a petition he or she shall designate to the secretary
of state the name and address of the person to whom any notices shall be sent
pursuant to sections 116.140 and 116.180 and, if a committee or person,
except the individual submitting the sample sheet, is funding any portion
of the drafting or submitting of the sample sheet, the person submitting
the sample sheet shall submit a copy of the filed statement of committee
organization required under subsection 5 of section 130.021 showing the
date the statement was filed. The secretary of state shall refer a copy of the
petition sheet to the attorney general for his approval and to the state auditor
for purposes of preparing a fiscal note and fiscal note summary. The secretary
of state and attorney general must each review the petition for sufficiency
as to form and approve or reject the form of the petition, stating the reasons
for rejection, if any.
2. Within two business days of receipt of any such sample sheet, the
office of the secretary of state shall conspicuously post on its website the
text of the proposed measure, a disclaimer stating that such text may not
constitute the full and correct text as required under section 116.050, and
the name of the person or organization submitting the sample sheet. The
secretary of state’s failure to comply with such posting shall be considered
a violation of chapter 610 and subject to the penalties provided under
subsection 3 of section 610.027. The posting shall be removed within three
days of either the withdrawal of the petition under section 116.115 or the
rejection for any reason of the petition.
3. Upon receipt of a petition from the office of the secretary of state,
the attorney general shall examine the petition as to form. If the petition is
rejected as to form, the attorney general shall forward his or her comments
to the secretary of state within ten days after receipt of the petition by the
attorney general. If the petition is approved as to form, the attorney general
shall forward his or her approval as to form to the secretary of state within
ten days after receipt of the petition by the attorney general.
4. The secretary of state shall review the comments and statements of the
attorney general as to form and make a final decision as to the approval or
rejection of the form of the petition. The secretary of state shall send written
notice to the person who submitted the petition sheet of the approval within
fifteen days after submission of the petition sheet. The secretary of state shall
send written notice if the petition has been rejected, together with reasons for
rejection, within fifteen days after submission of the petition sheet.
(L. 1985 H.B. 543 § 1, A.L. 1997 S.B. 132, A.L. 2013 H.B. 117) Effective 11-04-14
(1991) That part of this section which limits submission to secretary of state of sample
petitions to one year prior to the final date for filing signed petitions shortens time authorized
by constitution, art. XII, sec. 2(b), during which constitutional amendment petitions may be
circulated for signatures and is invalid. State of Mo., ex rel. Upchurch v. Blunt, 810 S.W.2d 515
(Mo. banc).
33
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
708a
SC101805 Appeal Document Number 33 Page 36
116.334. Petition approval required, procedure to obtain petition title
or summary statement—rejection or approval of petition, procedure—
circulation of petition prior to approval, effect—signatures, deadline for
filing.—1. If the petition form is approved, the secretary of state shall make a
copy of the sample petition available on the secretary of state’s website. For
a period of fifteen days after the petition is approved as to form, the secretary
of state shall accept public comments regarding the proposed measure and
provide copies of such comments upon request. Within twenty-three days of
receipt of such approval, the secretary of state shall prepare and transmit to
the attorney general a summary statement of the measure which shall be a
concise statement not exceeding one hundred words. This statement shall be
in the form of a question using language neither intentionally argumentative
nor likely to create prejudice either for or against the proposed measure. The
attorney general shall within ten days approve the legal content and form of
the proposed statement.
2. Signatures obtained prior to the date the official ballot title is certified
by the secretary of state shall not be counted.
3. Signatures for statutory initiative petitions shall be filed not later than
six months prior to the general election during which the petition’s ballot
measure is submitted for a vote, and shall also be collected not earlier than
the day after the day upon which the previous general election was held.
(L. 1985 H.B. 543 § 2, A.L. 1997 S.B. 132, A.L. 2013 H.B. 117) *Effective 11-04-14
116.340. Publication of approved measures.—When a statewide ballot
measure is approved by the voters, the secretary of state shall publish it with
the laws enacted by the following session of the general assembly, and the
revisor of statutes shall include it in the next edition or supplement of the
revised statutes of Missouri. Each of the measures printed above shall include
the date of the proclamation or statement of approval under section 116.330.
(L. 1980 S.B. 658) Effective 1-1-81
34
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
709a
SC101805 Appeal Document Number 33 Page 37
Code of State Regulations
Title 15—Elected Officials
Division 30—Secretary of State
Chapter 15—Initiative, Referendum,
New Party, and Independent Candidate
Petition Rules
15 CSR 30-15.010 Signature Verification Procedures for
Initiative, Referendum, New Party, and Independent Candidate
Petitions
PURPOSE: The secretary of state may make rules to ensure uniform,
complete, and accurate checking of initiative and referendum petition
signatures. This rule provides for uniform determination of whether
signatures are those of legal voters as required in Article III, Section
50 of the Missouri Constitution.
(1) Voter signatures will be rejected if—
(A) They list an address outside of the county as indicated on
the petition except as provided in subsection (2)(B) and (3)(F) of this
section; or
(B) They have been struck through or crossed out.
(2) Voter names will only be accepted if—
(A) The name is exactly as it appears on the voting rolls except
that there is—
1. The presence or absence of a middle initial when a first name
is given or the presence or absence of a first initial when a middle
name is given;
2. The substitution of a common nickname for the name on the
voting roll, that is, Dick for Richard, Liz or Beth for Elizabeth, Bill
for William, Becky for Rebecca, etc.;
3. The presence or absence of terms such as Jr. or Sr. following
a name;
4. The use of only a first and middle initial provided that on
either the petition or the voting rolls both initials can be determined
from the name(s) given; and
5. A name change and the local election authority deter- mines
that the individual’s signature on the petition and on the voter’s
registration record are sufficiently alike to identify the petition
signer as the same person who is registered to vote; and
35
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
710a
SC101805 Appeal Document Number 33 Page 38
(B) They were registered to vote within the county named at the
top of the petition page on the date the petition was signed.
(3) Voter addresses will be accepted if they meet one (1) or a
combination of the following categories:
(A) The address is exactly as it appears on the voting rolls;
(B) The address is exactly as it appears on the voting rolls except
that there is—
1. The presence or absence of a letter or number identifying
an apartment; and
2. The presence or absence of a letter or grouping of letters
indicating the directional location of a street, for example, “E” for
east, “NW” for northwest, “S” for south;
(C) The voter resides in the same residence as indicated on the
voting rolls and the local election authority can determine that only
the address designation has been changed by municipal or postal
authorities;
(D) The address as listed on the petition was the voter’s
registered address on the date the petition was signed;
(E) The address listed on the petition is different from the
address on the voting rolls but within the county named at the
top of the page, provided that the local election authority who
maintains the registration record of such person shall compare
and determine that the individual’s signatures on the petition and
on the voter’s registration record are sufficiently alike to identify the
petition signer as the same person who is registered to vote within
the jurisdiction. If otherwise valid, the signature of an individual
whose address is acceptable under this subsection (3)(E) shall
be counted in the totals of the local election authority who has
jurisdiction over the address listed on the petition; or
(F) The address listed on the petition is different from the
address on the voting rolls but the voter was registered to vote
within the county named at the top of the page on the date the
petition was signed, provided that the local election authority who
maintains the registration record of such person shall compare
and determine that the individual’s signatures on the petition and
on the voter’s registration record are sufficiently alike to identify
the petition signer as the same person who was registered to
vote within the jurisdiction on the date the petition was signed.
If otherwise valid, the signature of an individual whose address
is acceptable under this subsection (3)(F) shall be counted in the
totals of the local election authority who has jurisdiction over the
address named at the top of the petition page.
36
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
711a
SC101805 Appeal Document Number 33 Page 39
(4) A voter’s signature will be accepted as valid if it generally appears
to be in a form similar to that found on the voter rolls.
(5) In order for a name to be qualified to appear on the petition,
there must be a valid voter name, address, and signature. NOTE:
Failure of any other information is not a reason to fail to certify a
name as being qualified.
(6) A voter’s signature shall not be deemed invalid on the basis of
source of registration. If otherwise valid, the signature of a person
who registered to vote pursuant to the provisions of sections
115.159, 115.160, or 115.162, RSMo, shall be accepted as valid
without respect to whether such person has previously voted in
the jurisdiction or received a voter identification card, provided that
each of the following must apply at the time of verification of the
petition by the local election authority:
(A) The voter registration application had been received and
accepted by the election authority on or before the date the petition
was signed;
(B) The verification notice sent by the election authority
pursuant to section 115.155.3, RSMo, was not returned by the
postal service to the election authority within the time established
by the election authority; and
(C) The local election authority’s voter registration file reflects
the applicant was eligible to vote in the county named at the top of
the petition page on the date the petition was signed.
AUTHORITY: section 115.335.7, RSMo Supp. 2023, and section
116.130.5, RSMo 2016.* Original rule filed Nov. 22, 1985, effective
March 24, 1986. Amended: Filed April 22, 1992, effective Sept. 6,
1992. Emergency amendment filed June 10, 1992, effective June
20, 1992, expired Oct. 17, 1992. Emergency amendment filed July
9, 1996, effective July 19, 1996, expired Jan. 14, 1997. Amended:
Filed July 9, 1996, effective Feb. 28, 1997. Amended: Filed Aug.
27, 1999, effective Feb. 29, 2000. Amended: Filed Aug. 30, 2013,
effective Feb. 28, 2014. Amended: Filed Nov. 29, 2023, effective June
30, 2024.
*Original authority: 115.335.7, RSMo 1977, amended 1993, 1995,
2018, and 116.130, RSMo 1980, amended 1988, 1995, 1997, 1999,
2003.
15 CSR 30-15.020 Processing Procedures for Initiative,
Referendum, New Party, and Independent Candidate Petitions
PURPOSE: The secretary of state may make rules to ensure uniform,
complete, and accurate checking of initiative and referendum petition
37
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
712a
SC101805 Appeal Document Number 33 Page 40
signatures. This rule provides for uniform processing of petitions
once a determination has been made as to the validity of a name on
a petition.
(1) Each local election authority shall check each signature
designated by the secretary of state against voter registration
records and annotate each signature, according to their findings
in red ink in the left margin, on the copies of petition pages sent to
him/her in the following manner:
(A) If the name, address, and signature are acceptable pursuant
to 15 CSR 30-15.010 “R” to denote “Registered”;
(B) Where possible, if the voter’s address on an “R” designated
signature is acceptable pursuant to 15 CSR 30-15.010 (3)(F), where
the address listed on the petition is different from the address
on the voting rolls but the voter was registered to vote within
the county named at the top of the petition page on the date the
petition was signed, and the local election authority determined
that the individual’s signatures on the petition and on the voter’s
registration record are sufficiently alike to identify the petition
signer as the same person who was registered to vote within the
jurisdiction on the date the petition was signed, the local election
authority listed on the top of the petition page shall designate the
signature as “R”;
(C) Where possible, if the voter’s address on an “R” designated
signature is acceptable pursuant to 15 CSR 30-15.010(3)(E), where
the address listed on the petition is different from the address on
the voting rolls (including PO Box addresses) but within the county
named at the top of the page, and the local election authority
determined that the individual’s signatures on the petition and
on the voter’s registration record are sufficiently alike to identify
the petition signer as the same person who is registered to vote
within the jurisdiction, the local election authority shall add to the
“R” designation “DA” (i.e., “RDA” to denote “Registered, Different
Address”);
(D) If the name on the petition does not appear in the election
authority’s registration file as an eligible voter in that jurisdiction
“NR” to denote “Not Registered”;
(E) If the name and address are acceptable pursuant to 15 CSR
30-15.010, but the signature appears different than that on file
with the election authority, “WS” to denote “Wrong Signature”;
(F) If a name selected in a random sample for a particular
congressional district is actually in another district in the county
38
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
713a
SC101805 Appeal Document Number 33 Page 41
and otherwise properly registered, “OD” to denote “Other District”;
and
(G) If a person is registered, but the correct congressional district
is not indicated on the petition, the incorrect number should be
crossed out and the correct number entered in the right margin.
(2) In the event a duplicate signature is found on the petition,
the local election authority shall call this to the attention of the
secretary of state in a separate memo, noting the page number(s)
and the line number(s) of the signatures.
(3) In the event a situation is identified where one (1) person has
signed for him/herself and his/her spouse on one (1) line, that is,
Mr. and Mrs. John Jones, the signature may be counted which
appears to be that of the petition signer provided that all of the
requirements of sections (1) and (2) are met. The local election
authority shall call these occurrences to the attention of the
secretary of state in a separate memo, noting the page number(s)
and the line number(s).
(4) Each local election authority shall review all pages and signatures
s/he had been asked to check by the secretary of state for apparent
irregularities and call these irregularities to the attention of the
secretary of state in a separate memo, noting the page number(s)
and the line number(s).
(5) Each local election authority shall certify to the secretary of state,
on forms provided, or by means of petition processing summary
reports generated by the software provided by the secretary of state
as part of the Centralized Voter Registration System authorized by
section 115.158, RSMo, the total of each category enumerated in
section (1) less the number of duplicate, but otherwise qualified,
signatures in section (2). First class counties participating in
the Centralized Voter Registration System through the electronic
interface allowed by the statute may certify their totals on reports
from their automated systems if the report format is approved by
the secretary of state.
AUTHORITY: section 115.335.7, RSMo Supp. 2023, and section
116.130.5, RSMo 2016.* Original rule filed Nov. 22, 1985, effective
March 24, 1986. Amended: Filed April 22, 1992, effective Sept. 6,
1992. Emergency amendment filed June 10, 1992, effective June
20, 1992, expired Oct. 17, 1992. Emergency amendment filed July
12, 1996, effective July 22, 1996, expired Jan. 14, 1997. Amended:
Filed July 12, 1996, effective Feb. 28, 1997. Amended: Filed Aug.
27, 1999, effective Feb. 29, 2000. Amended: Filed Aug. 30, 2013,
39
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
714a
SC101805 Appeal Document Number 33 Page 42
effective Feb. 28, 2014. Amended: Filed Nov. 29, 2023, effective June
30, 2024.
*Original authority: 115.335.7, RSMo 1977, amended 1993, 1995,
2018, and 116.130, RSMo 1980, amended 1988, 1995, 1997, 1999,
2003.
15 CSR 30-15.030 Initiative, Referendum, New Party, and
Independent Candidate Petitions Missouri Voter Registration
System and Other Computerized Processing Options
PURPOSE: The purpose of this rule is to clarify that local election
authorities have the option to use the centralized Missouri Voter
Registration System (MCVR) or a petition processing software
program provided and maintained by the Office of the Secretary
of State for initiative, referendum, new party, and independent
candidate petition signature verification as allowed under Chapters
115 and 116, RSMo. MCVR is the official statewide voter registration
list which was created and implemented as part of the Help America
Vote Act of 2002. This system is maintained and administered
by the Office of the Secretary of State and contains the name and
registration information of every legally registered Missouri voter.
It serves as the official voter registration list for the conduct of all
elections in Missouri and allows local election authorities immediate
real-time electronic access to the information contained in the system.
Currently, local election authorities may use this system for petition
signature verification as authorized by Chapter 115, RSMo. The
secretary of state may make rules to ensure uniform, complete, and
accurate checking of initiative and referendum petition signatures.
(1) Each local election authority has the option for local petitions
to comply with the requirements of 15 CSR 30-15.010 and 15 CSR
30-15.020 through the centralized Missouri Voter Registration
System (MCVR).
(2) Each local election authority may comply with the requirements of 15 CSR 30-15.010 and 15 CSR 30-15.020 for statewide
petitions, referendums, new party, and independent candi- dates
filed with the secretary of state office through a petition processing
software program maintained and administered by the secretary of
state. Petition pages will be processed and annotated electronically.
Each local election authority shall certify to the secretary of state
by means of petition processing summary reports generated by the
software program provided by the secretary of state the total of
each category enumerated in 15 CSR 30-15.020(1) less the number
of duplicate, but other- wise qualified, signatures in 15 CSR 3015.020(2).
40
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
715a
SC101805 Appeal Document Number 33 Page 43
AUTHORITY: section 115.335.7, RSMo Supp. 2023, and section
116.130.5, RSMo 2016.* Original rule filed Aug. 14, 2013, effective
Feb. 28, 2014. Amended: Filed Jan. 31, 2020, effective July 30,
2020. Amended: Filed Nov. 29, 2023, effective June 30, 2024.
*Original authority: 115.335.7, RSMo 1977, amended 1993, 1995,
2018, and 116.130, RSMo 1980, amended 1988, 1995, 1997, 1999,
2003.
Contact Information
Physical Address:
600 West Main Street
Jefferson City, MO 65101
Telephone:
(800) 669-8683
(573) 751-2301
FAX:
(573) 526-3242
Email:
elections@sos.mo.gov
Website:
www.sos.mo.gov/elections
41
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
716a
SC101805 Appeal Document Number 33 Page 44
717a
Stipulated Exhibit 12
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
SC101805 Appeal Document Number 34 Page 1
FOR IMMEDIATE RELEASE
October 15, 2025
Secretary of State Approves Redistricting Referendum for Circulation
Missouri Secretary of State Denny Hoskins announced that a referendum petition seeking to repeal recently
enacted redistricting legislation has been approved for circulation.
The Secretary’s approval authorizes the sponsor to begin collecting signatures from registered Missouri voters.
Under Missouri law, no signatures gathered before this approval date are valid, and doing so constitutes a
misdemeanor election offense.
“The process is clear,” said Secretary Hoskins. “Every Missourian deserves confidence that ballot measures
follow the law — not out-of-state agendas or confusion campaigns. Missouri values fairness and integrity, and
this process reflects that.”
The referendum, submitted under 2026-R004, seeks to refer to voters a bill passed during the 2025 Second
Extraordinary Special Session of the Missouri General Assembly. The full text of the measure, the official ballot
title, and the approved circulator instructions are available on the Secretary of State’s website
at www.sos.mo.gov/elections/petitions.
To qualify for the November 2026 general election ballot, proponents must collect signatures from at least 5% of
registered voters in six of Missouri’s eight congressional districts by the statutory deadline.
“This office remains committed to transparency, accuracy, and protecting Missouri voters’ trust in the democratic
process,” Hoskins said.
The approval packet has been attached for reference.
About the Missouri Secretary of State’s Office
The Secretary of State’s Office oversees Missouri’s elections, business registrations, securities, and state
libraries and archives. For more information on the petition process, visit sos.mo.gov/elections.
2026-R004 Approval Packet.pdf
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
718a
SC101805 Appeal Document Number 34 Page 2
719a
Stipulated Exhibit 13
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
SC101805 Appeal Document Number 35 Page 1
FOR IMMEDIATE RELEASE
October 16, 2025
Statement from Secretary of State Denny Hoskins Regarding Referendum Petitions
“Our office’s duty is to uphold both the Constitution and the statutes that protect the integrity of Missouri’s
elections,” said Secretary Hoskins. “We will continue to defend every citizen’s right to petition their government—
while also ensuring that those who deliberately commit fraud or forgery in the process are held accountable.
Allowing out-of-state individuals to abuse the process and cheat undermines Missouri citizen’s power in our
political process.”
The right of Missourians to speak freely and to petition their government is fundamental. Merely advocating for
or discussing a referendum, or engaging with others about potential ballot issues, is not a crime and never has
been. Nor is seeking signatures before the proposed referendum is approved as to form—even if those
signatures cannot be counted due to noncompliance with statutory rules. The Secretary of State fully supports
Missourians’ constitutional rights to express their opinions and to organize around issues of public concern.
Recent statements from the Office have focused not on restricting that right, but on reminding the public of the
specific criminal offenses that may occur during the signature-gathering phase of a referendum petition once
circulation begins under Missouri law.
Those offenses—defined in Chapters 115 and 116 of the Missouri Revised Statutes—include:
Signing a petition using any name other than one’s own;
Knowingly signing more than once for the same measure or election;
Signing a petition while not a registered Missouri voter;
Falsifying or forging signatures;
Submitting petition sheets known to contain false or invalid signatures;
Accepting or offering money or anything of value in exchange for a signature;
Falsely swearing to a circulator’s affidavit or notarization; and
Knowingly filing false withdrawal or affidavit statements.
“Every Missourian has the right to advocate, sign, and participate—but no one has the right to cheat,” Hoskins
said. “If any citizen witnesses violations of these laws in the field, they can report them
at: https://www.sos.mo.gov/elections/elections_integrity.”
Each of these actions is a violation of state election law and may carry criminal penalties. The following table
summarizes the applicable statutes and classifications:
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
720a
SC101805 Appeal Document Number 35 Page 2
721a
Statute
Offense
Class / Penalty
§ 116.030 / .040 False or multiple signatures on petition
Class A Misdemeanor
§ 116.080
False circulator affidavit / forgery history
Class A Misdemeanor
§ 116.090
Petition signature fraud (false names, forged sheets,
payments)
Class A Misdemeanor
§ 116.110
False signature-withdrawal statement
Class A Misdemeanor
§§ 115.631 –
115.637
False oath, bribery, intimidation, or election fraud (acts
connected with suffrage)
Class One – Class Three Election Offense (Felony to Misdemeanor
depending on conduct)
§ 115.639
Interfering with an employee’s right to vote (three hours off
work)
Class Four Election Offense (Misdemeanor)
The Secretary emphasized that transparency, accuracy, and lawful participation remain the guiding principles of
the referendum and initiative processes.
If any Missouri citizen witnesses potential violations of these laws in the field, they are encouraged to report them
at www.sos.mo.gov/elections/elections_integrity.
For additional information about Missouri’s referendum petition procedures,
visit www.sos.mo.gov/elections/petitions.
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
SC101805 Appeal Document Number 35 Page 3
722a
Stipulated Exhibit 14
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
SC101805 Appeal Document Number 36 Page 1
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
723a
SC101805 Appeal Document Number 36 Page 2
8/10/26, 10:27 AM
Missouri redistricting plan may be frozen past 2026 election cycle | STLPR
On the Trail
On the Trail, an occasional column by St. Louis Public Radio political reporter Jason Rosenbaum, takes
an analytical look at politics and policy across Missouri.
Missouri Republicans learn that redrawing
congressional lines isn’t so easy
St. Louis Public Radio | By Jason Rosenbaum
Published Oct. 28, 2025 at 5:00 a.m. CDT
LISTEN • 4:19
Brian Munoz / St. Louis Public Radio
https://www.stlpr.org/government-politics-issues/2025-10-28/missouri-republicans-redrawing-congressional-lines-redistricting-trump
1/12
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
724a
SC101805 Appeal Document Number 36 Page 3
8/10/26, 10:27 AM
Missouri redistricting plan may be frozen past 2026 election cycle | STLPR
Senate President Pro Tem Cindy O'Laughlin, R-Shelbina, during a special session on Sept. 10 at the state Capitol in
Jefferson City.
Republicans in the Missouri legislature passed a new congressional map last month as part of a
national GOP strategy to prevent Democrats from taking control of the U.S. House.
But a looming referendum could derail plans to implement new congressional lines aimed at
ousting Democratic Congressman Emanuel Cleaver — even if voters approve the map in
November 2026.
Since the map passed, redistricting foes have filed a flurry of lawsuits and started collecting
signatures to let voters decide on the plan in the November 2026 election cycle. While it is
hypothetically possible for the legislature to move the referendum, Missouri Republicans are
recognizing that the statewide vote may torpedo any hope of having the lines in place for the
2026 elections.
And while Republican statewide officials are trying to throw up legal and procedural roadblocks,
Democratic lawmakers and GOP legislators who declined to support the redistricting plan say
this highly contentious chapter in Missouri’s political history showcases the pitfalls of acceding
to pressure from President Donald Trump and his administration.
“When you nationalize what we normally do here in Missouri … and then you let somebody else
do that, in this case the president's administration, you're going to have screw-ups,” said Senate
Minority Leader Doug Beck, D-St. Louis County. “They're not going to know all the laws of
Missouri and what we go through.”
Despite the uncertainty, other Republicans say they have no regrets about pushing the highly
contentious congressional redrawing forward — even with the Democratic counterattack
casting doubt if the proposal will go into effect.
“You can't bring a knife to a gunfight. And I think that's why people ultimately said, ‘Well, we
need to at least try to do whatever we can to maintain the majority now,'” said Senate President
Pro Tem Cindy O’Laughlin, R-Shelbina. “The people in Washington in the Democrat Party are
radicals, and it's very frightening to the majority of people in Missouri to think about that.”
https://www.stlpr.org/government-politics-issues/2025-10-28/missouri-republicans-redrawing-congressional-lines-redistricting-trump
2/12
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
725a
SC101805 Appeal Document Number 36 Page 4
8/10/26, 10:27 AM
Missouri redistricting plan may be frozen past 2026 election cycle | STLPR
Tristen Rouse / St. Louis Public Radio
Fog rises off the Missouri River in front of the state Capitol on the morning of Jan. 3, 2024, in Jefferson City.
Roots of a referendum
Missouri became the second Republican-leaning state to redraw its congressional lines this
year. It happened after Trump pressured Texas to redraw its map — which prompted California
to place a measure before voters that could create more Democratic seats. Other states could
soon revisit their congressional seats in the coming months.
“I wish I hadn't had to vote for it, but I don't regret my vote,” said Rep. Jim Murphy, R-south St.
Louis County. “I see what other states have done, and it's appalling. Tit for tat is not a good way
to run a state, or a country for that matter. But unfortunately, it's the environment.”
The origins of Missouri Republicans’ redistricting complications are in the vote count in the
House and Senate.
Since Missouri Republicans hold commanding majorities in both chambers, the legislature was
able to break through Democratic opposition and send the map to Kehoe in September.
Because there weren’t enough House or Senate votes to make the new map go into effect right
away, the plan was subject to a referendum.
https://www.stlpr.org/government-politics-issues/2025-10-28/missouri-republicans-redrawing-congressional-lines-redistricting-trump
3/12
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
726a
SC101805 Appeal Document Number 36 Page 5
8/10/26, 10:27 AM
Missouri redistricting plan may be frozen past 2026 election cycle | STLPR
Are Missouri Republicans haunted by
redistricting bid? Some have regrets,
others hold strong
LISTEN • 14:46
The group People Not Politicians said it's already collected 100,000 signatures in roughly a
month — which bodes well for the effort to collect more than 106,000 signatures in six of the
state's eight congressional districts. If People Not Politicians collects enough signatures, the
map cannot take effect unless voters approve the measure in a statewide election in November
2026. That would mean the current districts would remain in place during next year’s elections.
Rep. Bryant Wolfin, R-Ste. Genevieve, who voted against the redistricting plan, said he didn’t
know that a referendum on the new lines was possible before the special session. He said, “I
guarantee the majority of the caucus did not as well.”
“I think just given how fast all this was kind of rushed through and, honestly, we weren't really
prepared a whole lot coming in,” Wolfin said.
Unlike with proposed constitutional amendments, only the General Assembly, and not the
governor, has the power to move the date of a referendum. That happened in 2018 when
lawmakers shifted a vote on right-to-work legislation from November to August.
But in order for the map to go into effect before filing closes for the 2026 election, lawmakers
would have to make the referendum occur before March 31. Not only is it rare for statewide
contests to occur in any month besides August or November, state law says that there needs to
be notice of an election 10 weeks before it's held. That makes it basically impossible for the
legislature to move the referendum to March — even at the very beginning of the legislative
session.
Even if it was possible, legislative leaders aren’t wild about the idea of moving the referendum
date — especially since they say the map could get voted down in a low-turnout election in
which redistricting foes are more energized than redistricting proponents.
“I always prefer a larger-turnout election, because it gives you a better feel for what the citizens
of Missouri as a whole are thinking,” said House Speaker Pro Tem Chad Perkins, R-Bowling
Green. “Why would you do it in March or April, when you get 15% or 16% turnout, when you
could do it later on that year and get 60% turnout? I think November is probably a better option.”
https://www.stlpr.org/government-politics-issues/2025-10-28/missouri-republicans-redrawing-congressional-lines-redistricting-trump
4/12
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
727a
SC101805 Appeal Document Number 36 Page 6
8/10/26, 10:27 AM
Missouri redistricting plan may be frozen past 2026 election cycle | STLPR
Annelise Hanshaw / Missouri Independent
Missouri Secretary of State Denny Hoskins speaks to reporters in May 2024 during his time as a state senator.
‘We are in a lot of new territory’
With the stakes of just securing the referendum signatures so high, Secretary of State Denny
Hoskins and Attorney General Catherine Hanaway are placing roadblocks to prevent the
measure from getting to voters.
Hoskins approved the referendum for circulation but said that any signatures gathered before
mid-October won’t count toward the final tally.
“We are in a lot of new territory, with a referendum, with redistricting mid-census and things like
that,” Hoskins said in an interview earlier this month. “I believe that based on the Missouri
Constitution as well as Missouri state law, that we are in the right and we're going to protect the
Missouri Constitution.”
People Not Politicians officials strongly disagree with that contention and plan to fight to prevent
100,000 signatures from being tossed out.
“Missouri politicians continue to try to confuse, intimidate and, frankly, silence us. Specifically
the attorney general and secretary of state have been deliberately confusing the initiative
petition process and the referendum process,” said People Not Politicians Executive Director
Richard von Glahn. “These are frankly deliberate misrepresentations by elected officials who
should know better.”
https://www.stlpr.org/government-politics-issues/2025-10-28/missouri-republicans-redrawing-congressional-lines-redistricting-trump
5/12
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
728a
SC101805 Appeal Document Number 36 Page 7
8/10/26, 10:27 AM
Missouri redistricting plan may be frozen past 2026 election cycle | STLPR
In addition to defending the redrawn map against several lawsuits in court, Hanaway is asking a
federal court to bar People Not Politicians from pursuing its referendum. Among other
arguments, she contends that putting the map up for a vote is unconstitutional.
A statement from her office says that the “Missouri Constitution and the U.S. Constitution vests
the authority for congressional redistricting in the General Assembly, not activist organizations
funded by outside interests.”
“Attorney General Hanaway is upholding the U.S. Constitution by ensuring that Missouri’s
redistricting process remains in the hands of the officials chosen by Missouri voters,” the
statement from her office says. “The Office will continue fighting to protect the integrity of
Missouri’s elections and preserve the rule of law against efforts to usurp the power of the
people’s representatives.”
Chuck Hatfield, an attorney for People Not Politicians, said Hanaway’s lawsuit papers over a
1916 Supreme Court decision that upheld a bid to place a redistricting plan up for a referendum.
He and other People Not Politicians officials note that Missourians have voted before on a
redistricting plan, in a referendum in 1922.
Hatfield also said Hanaway’s lawsuit uses dissents from Supreme Court justices to make its
arguments, which are not binding precedent. That, he said, cuts at Hanaway’s argument that
only the General Assembly can delegate its power over redistricting.
“The law in the United States right now, according to the United States Supreme Court, is that
the people have the right to take back congressional redistricting completely,” Hatfield said. “In
Arizona, they took away the right of the legislature to draw the lines at all. It was done by a
citizen commission. A majority of the United States Supreme Court said that did not violate [the
U.S. Constitution’s Elections Clause]. There is a dissent that objects to that and says that it
would violate that. But that's not the law today.”
Republican political consultant John Hancock said Hanaway’s argument is plausible. But he
added that redistricting opponents are arguing that the Missouri Constitution doesn’t explicitly
authorize lawmakers to redraw districts in the middle of the decade — which is fairly similar to
Hanaway's contention in trying to prevent a referendum.
He said it’s likely that legal and procedural disagreements over the new map won’t be resolved
anytime soon.
“I'll be surprised if come filing in February, if this thing is resolved in such a way that the new
lines are governing,” Hancock said.
https://www.stlpr.org/government-politics-issues/2025-10-28/missouri-republicans-redrawing-congressional-lines-redistricting-trump
6/12
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
729a
SC101805 Appeal Document Number 36 Page 8
8/10/26, 10:27 AM
Missouri redistricting plan may be frozen past 2026 election cycle | STLPR
Brian Munoz / St. Louis Public Radio
Rep. Bryant Wolfin, R-Ste. Genevieve, voted against a plan to redraw the state's congressional districts.
Any regrets?
Wolfin said that the complications over implementing the redistricting plan should give pause to
other states considering redrawing their maps, like Indiana and Kansas.
In particular, Wolfin said the issue showcases the dangers of letting a state legislature effectively
take orders from the federal government — even if the executive branch has similar political
aims as the state legislative majority.
“We are sovereign states. We are independent states. We are allowed to be able to voice our
own opinions, and we certainly do not have to pander to what they need at the federal level,”
Wolfin said.
O’Laughlin said nobody should be surprised that Democrats are pushing back against the
redistricting plan — especially with so much on the line during the 2026 election cycle.
She said she has no regrets about pushing the map through the Senate, which involved using a
procedural move called the previous question to end a Democratic filibuster.
“People understand that the number of representatives that you have in Washington can make a
huge difference,” O’Laughlin said. “I guess I don't have to remind you, or really anybody listening
https://www.stlpr.org/government-politics-issues/2025-10-28/missouri-republicans-redrawing-congressional-lines-redistricting-trump
7/12
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
730a
SC101805 Appeal Document Number 36 Page 9
8/10/26, 10:27 AM
Missouri redistricting plan may be frozen past 2026 election cycle | STLPR
to this, that in the current environment everything is war. So I'm not surprised when shots start
getting fired.”
Have a question or comment about this story? Email St. Louis Public Radio.
Got a news tip? Send it to Jason Rosenbaum.
Tags
Government , Politics & Issues
On the Trail
Top Stories
Missouri redistricting
Doug Beck
Chad Perkins
Audio Features
Br yant Wolfin
Cindy O'Laughlin
Jason Rosenbaum
Jason is the politics correspondent for St. Louis Public Radio.
See stories by Jason Rosenbaum
Latest Stories
Sports
'Your track is back’: Belle-Clair Speedway is hoping to book 15-18 days of racing in
2027
News Briefs
Westbound I-64 in East St. Louis to close for over a week beginning this weekend
https://www.stlpr.org/government-politics-issues/2025-10-28/missouri-republicans-redrawing-congressional-lines-redistricting-trump
8/12
731a
Stipulated Exhibit 15
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
SC101805 Appeal Document Number 37 Page 1
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
732a
SC101805 Appeal Document Number 37 Page 2
8/10/26, 10:28 AM
Hoskins faces another lawsuit in Missouri congressional redistricting saga | STLPR
Group asks judge to force Missouri
secretary of state to decide on redistricting
referendum
St. Louis Public Radio | By Jason Rosenbaum
Published May 18, 2026 at 6:05 p.m. CDT
Jason Rosenbaum / St. Louis Public Radio
Secretary of State Denny Hoskins welcomes candidates who filed for office in Jefferson City on Feb. 24. The group
behind a redistricting referendum filed a lawsuit on Monday asking a judge to force Hoskins to decide on whether it
will make the November 2026 ballot.
https://www.stlpr.org/government-politics-issues/2026-05-18/group-asks-judge-force-missouri-secretary-of-state-decide-redistricting-referendum
1/8
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
733a
SC101805 Appeal Document Number 37 Page 3
8/10/26, 10:28 AM
Hoskins faces another lawsuit in Missouri congressional redistricting saga | STLPR
Secretary of State Denny Hoskins is facing another lawsuit over a congressional map passed in
2025.
People Not Politicians Executive Director Richard von Glahn filed suit on Monday in Cole
County Court to force Hoskins to either accept or reject the group's referendum on the new
congressional lines. He also wants a Cole County judge to stop Hoskins and Attorney General
Catherine Hanaway from mandating that local elections officials implement the map aimed at
ousting Democratic Congressman Emanuel Cleaver.
“Because Defendant Hoskins has abdicated his duties, Plaintiffs bring this suit to force him to do
them, ensure that Plaintiff von Glahn and countless other Missourians are able to cast legal
votes in the correct congressional districts, and restore sanity and decorum to Missouri’s
electoral process,” the lawsuit states.
The suit is, in some respects, part of the aftermath of a unanimous Missouri Supreme Court
decision in another lawsuit that the submission of signatures from People Not Politicians didn’t
automatically suspend the new map. Hoskins told reporters that he plans to wait until late July
or early August to decide on the referendum.
But von Glahn is asking a judge to make Hoskins accept or reject the referendum immediately,
especially since he’s already filed federal court documents and made public statements that he
thinks that a redistricting referendum is unconstitutional.
“We're still doing some research,” Hoskins said last Friday. “I do have some constitutionality
concerns that … the referendum was never meant for congressional redistricting.”
If Hoskins rejects the referendum now, the lawsuit states, it would give von Glahn adequate time
to appeal the decision — and, perhaps, provide certainty for the state’s elections officials.
https://www.stlpr.org/government-politics-issues/2026-05-18/group-asks-judge-force-missouri-secretary-of-state-decide-redistricting-referendum
2/8
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
734a
SC101805 Appeal Document Number 37 Page 4
8/10/26, 10:28 AM
Hoskins faces another lawsuit in Missouri congressional redistricting saga | STLPR
Brian Munoz / St. Louis Public Radio
Voters take to the polls at Ladue City Hall in Ladue in the early morning on Nov. 8, 2022, for midterm elections.
Suit asks for an end to ‘bullying’ elections officials
The suit also wants a judge to prevent Hoskins and Hanaway from making local elections
officials implement the 2025 map. That stems from a letter Boone County Clerk Brianna Lennon
sent to Hoskins saying her residents would vote under a map lawmakers approved in 2022 until
he decides on the referendum.
In response, Hanaway and Hoskins have blasted Lennon — and said that she may face civil or
criminal legal action.
“I think obviously there will be a lot of legal lawsuits, including some probably from the attorney
general's office, maybe from the Department of Justice, if she decides to defy the Supreme
Court order, defy the opinion from the attorney general and defy direction from the chief
election officer,” Hoskins said last Friday.
But the filing notes that the Missouri Supreme Court decision doesn’t say anything about
elections officials being required to implement the 2025 map. It also points to part of Missouri
Supreme Court Judge Ginger Gooch’s decision specifying that because Hoskins hasn’t made a
decision on whether to accept or reject the referendum, “it is impossible to say as of this
opinion” if People Not Politicians’ filing of signatures triggered the suspension of the 2025 map.
https://www.stlpr.org/government-politics-issues/2026-05-18/group-asks-judge-force-missouri-secretary-of-state-decide-redistricting-referendum
3/8
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
735a
SC101805 Appeal Document Number 37 Page 5
8/10/26, 10:28 AM
Hoskins faces another lawsuit in Missouri congressional redistricting saga | STLPR
And von Glahn’s lawsuit goes on to say that Hanaway and Hoskins are “attempting to bully and
intimidate local election officials into implementing congressional districts that — per the
Missouri Supreme Court’s opinion and the evidence — should be deemed suspended as of
December 9, 2025.”
“Because it is impossible to know whether HB 1 is the law, it is not lawful for Defendant Hoskins
to direct that it be used to conduct the primary elections for Congress,” the lawsuit states.
A spokeswoman for Hoskins said the Republican official is reviewing the lawsuit along with
lawyers from the attorney general’s office.
Hanaway spokeswoman Stephanie Whitaker said in a statement that the lawsuit “re-litigates the
exact same questions the Missouri Supreme Court just decided.”
“We look forward to prevailing in court,” Whitaker said.
Have a question or comment about this story? Email St. Louis Public Radio.
Got a news tip? Send it to Jason Rosenbaum.
Tags
Government , Politics & Issues
People Not Politicians
Denny Hoskins
Missouri redistricting
2026 Missouri elections
Top Stories
Catherine Hanaway
Jason Rosenbaum
Jason is the politics correspondent for St. Louis Public Radio.
See stories by Jason Rosenbaum
Latest Stories
https://www.stlpr.org/government-politics-issues/2026-05-18/group-asks-judge-force-missouri-secretary-of-state-decide-redistricting-referendum
4/8
736a
Stipulated Exhibit 16
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
SC101805 Appeal Document Number 38 Page 1
737a
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
SC101805 Appeal Document Number 38 Page 2
738a
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
SC101805 Appeal Document Number 38 Page 3
739a
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
SC101805 Appeal Document Number 38 Page 4
740a
Stipulated Exhibit 17
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
SC101805 Appeal Document Number 39 Page 1
284
MISSOURI
MANUAL
VOTE FOR PROPOSITIONS CAST AT T H E GENERAL ELECTION
N O V E M B E R 7, 1922—Continued.
Thirteenth
proposition.
Fourteenth
proposition.
Fifteenth
proposition.
Yes.
No.
Yes.
No.
Yes.
No.
3,050
1.137
6.351
3.993
1.453
2.835
2,262
1,073
2.993
3,056
859
3,687
625
3,698
3,117
1 ,199
802
1.220
2.344
1,380
2,459
49,957
1,304
297
10,711
1,388
40"
543
776
430
365
898
327
1,23!'
434
1,149
1,347
619
470
492
659
384
712
63,285
2.956
1 .155
6.05
,022
,461
.304
,23S
.082
.004
,971
861
3,738
626
3,647
3,071
1.198
77!'
1,236
2,335
1,404
2,448
49,492
1,,267
291
10,520
1,309
408
526
773
432
345
887
326
1,239
429
1,156
1,336
600
465
475
659
376
722
62,634
3.015
1,147
6,272
4,027
1.446
2.308
2,263
1.082
3.002
3,001
857
3,713
013
3.095
3.045
1,207
787
1,229
2.339
1.420
2.446
50.534
234,288 386,680
232,704
386,663
230,917
386,315
Counties.
St. Francois
Ste. Genevieve. .
St. I.ouis
Saline
Schuyler
Scotland
Seott
Shannon
Shelby
Stoddard
Stone
Sullivan
Taney
Texas
Vernon
Warren
Washington
Wayne
Webster
Worth
Wright
City of St. Louis.
Totals
, 259
307
,504
.414
412
547
802
460
361
912
33 S
,280
445
,162
,413
616
474
507
673
384
714
63 ,133
Proposition No. 13—Abolishing t h e offices of justices of t h e peace elected in townships
eonl ainfng a city of one h u n d r e d t h o u s a n d i n h a b i t a n t s and less t h a n three h u n d r e d t h o u s a n d .
Proposition N o . 14—Repealing article I X , c h a p t e r 22. R. S. 1919.
Proposition N o . 15—Amending t h e existing law so as to provide t h a t t h e c o u n t y c o u r t
m a y not a p p o i n t additional justices of t h e peace in certain townships.
VOTE F O R P R O P O S I T I O N S C A S T A T T H E G E N E R A L E L E C T I O N
N O V E M B E R 7, 1922—Continued.
Sixteenth
proposition.
Adair
Andrew
Atchison
Audrain
Barry
Barton
Bates
Benton
Bollinger
Boone
Buchanan
Butler
Caldwell
Callaway
Camden
Cape (iirardeau
Carroll
Carter
Cass
Cedar
Chariton
Christian
Clark
Clay
Clinton
Cole
Cooper
Crawford
Dado
Dallas
Daviess
DeKalb
Dent
Seventeenth
proposition.
Yes.
No.
Yes.
No.
1.24:
2,597
2,544
1,990
3,530
3,448
1,818
4,462
1,903
1,906
4,217
8.727
1.277
1.817
3,69:
1,28:
1,06
2.617
2.589
2,026
3,585
3,564
1,855
4,521
1.891
1.904
4,625
8.137
1,370
1,825
3,703
882
711
901
929
714
1,124
608
374
1,982
7,17:
1,429
1,174
644
245
826
876
949
776
1,242
688
431
1.758
7.406
1,425
1.2.il
956
679
291
1,406
1,808
3.527
3,041
1,471
1,865
3,570
3,031
1,399
3.52.
2,317
3,308
1.30:2.581
2.897
1,896
4.294
3.295
1,2 0
1,867
1,574
3.207
2,047
1.730
1,382
3,458
2,332
3,384
1,275
2.594
3.316
2.0.(4
4.494
3.312
1.271
1.889
1.719
3.229
2.048
1,737
172
514
664
515
7: (
1,126
89(
1.747
1,287
866
706
421
1,095
821
594
566
187
688
686
666
801
9 6
875
1,822
1,352
885
788
474
1.174
887
635
964
674
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
741a
SC101805 Appeal Document Number 39 Page 2
CONSTITUTIONAL
285
AMENDMENTS
VOTE FOR PROPOSITIONS CAST AT THE GENERAL ELECTION
NOVEMBER 7. 1922—Continued.
Sixteenth
proposition.
Counties.
Holt
Howell. . . .
Linn
Miller
....
Pettis. . . .
Phelps
Pike
Plat te
Polk
Ralls
Ray
St. Clair. . .
St. Louis
Sal 1 ne
Sh.lby
Sullivan
Seventeenth
proposition.
Yes.
No.
Yes.
478
58/
1,703
608
808
5,052
1,09/
897
1,381
344
1,107
682
1,294
34 1
4.717
42.47!.
4.823
1,637
1.4?*
661
91s
1,94!
1,8. 8
44.'
411
1,764
1,3:3
434
1.65.'
48-t
10,1.
1,48!
61/
661
384
701
366
94(
386
81/
1,123
2,081
241
36f
29-1
4S613
2,91i
85/
779
51.'
1,051
527
586,
25/
1,223
(IS
1(H
248
1,30,'
656
1,171
290
10,669
1,364
408
534
762
426
371
917
323
1,258
441
1.171
1,888
620
456
464
91!
1,8:-1
2,981
1.427
2.457
6.727
2.281
2.88!
4.263
1.197
2,012
2,526
2 . 1 S3
751
6,346
36,894
5,752
2.674
4,93!
2,444
2,2D
4,221
8 ,2. 7
2,54!
2,162
3,71.
3.291
2,OSO
4.97 s
1,107
1.576,
2.463
1.452
2,054
521
501
1,994
724
89/
5,15.'
1.15/
1.023
1,474
442
1.196,
6:«
1.34.'
31.1
4,179
40.49-4.923
1 .60S
1.612
691
981
1,85!
1,88*
522
478
1.822
1,341
4!"
1,719
4 SO
188
1,482
66.'
734
40/
771
391
1.01!
474
721
1.1.',:
2,177
2.-8
462
31i
50'
711
2,872
921
743
47l
1.141
561
68/
240
1.17!
601
113
268
1,341
74s
1.210
296
10,40(1
1,307
454
622
760
461
464
977
861
1,881
47S
1,247
1,377
773
482
500
84/
2,764
3,29/
2.50/
2.26/
1.78S
2,871
4.571
1.56/
3,0 1
854
1 .31!
2,422
5,0 2,004
2.466,
2,591
3,323
1.482
1,944
1,801
3,984
3,049
1.05S
1,656
2,139
3,326,
3,041
1.168
6.216
3,98*
1.402
2.291
2,248
1,089
2.98S
3,043
85!,
3,717
802
3,671
3,057
1,181
782
1,220
No.
958
1 949
2 974
1 389
2.518
7,000
2 302
2 913
4 352
1 977
2 609
2 212
773
37 731
8 002
2 722
4 980
2 458
2,250
3 809
2,271
3 699
5.1)05
1 145
1 576
2 058
879
2 802
2 562
2 227
1.K74
1 492
1 912
4 168
3 160
1 675
1,146
4,137
1,476
2 309
3,014
3,691
3 , 1 78
786
1,242
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
742a
SC101805 Appeal Document Number 39 Page 3
286
MISSOURI
MANUAL
VOTE FOR PROPOSITIONS CAST AT T H E GENERAL ELECTION
N O V E M B E R 7, 1922—Continued.
Counties.
Sixteenth
proposition.
Seventeenth
proposition.
Yes.
No.
Yes.
No.
686
371
708
63,033
2,291
1,406
2,451
49,158
822
404
758
63.646
2 281
231,601
382,915
240,340
386 522
2 441
Proposition N o . 16—Abolishing office of constable in certain townships.
Proposition N o . 17—Dividing State Into sixteen congressional districts.
VOTE FOR PROPOSITIONS CAST AT THE GENERAL ELECTION
N O V E M B E R 7. 1922—Continued.
Eighteenth
proposition.
Counties.
Adair
Andrew
Atchison
Audrain
Barry
Barton
Bates
Benton
Bollinger
Boone
Buchanan
Butler
Caldwell
Callaway
Camden
Cape Ciirardeau
Carroll
Carter
Cass
Cedar
Chariton
Christian
Clark
Clay
Clinton
Cole
Cooper
Crawford
Dade
Dallas
Daviess
DeKalb
Dent
Douglas
DunKlln
Franklin
Gasconade
Gentry
Greene
Grundy
Harrison
Henry
Hickory
Holt
11 oward
Howell
Iron
Jackson (outside Kansas City)
Kansas City
Jasper
Jefferson
Johnson
Knox
Laclede
Yes.
1,123
335
408
686
784
593
823
311
204
1,022
2,534
903
500
520
220
869
711
178
718
362
553
369
357
852
405
986
743
477
473
242
485
346
384
270
619
836
294
452
3,107
532
461
841
224
321
423
797
267
3,028
24,014
2,909
1,087
798
446
503
Nineteenth
proposition.
No.
Yes.
No.
3,329
3,978
2,911
4,088
4,176
2,504
5,656
2,609
2,235
5,893
18,696
2,869
3,108
4,169
1,019
4,928
4,860
1,197
1,015
2,540
2,549
1,929
3,561
3,411
1,839
4,546
1,947
1,856
4.506
7,946
1,288
1,789
3,608
653
4,881
2,825
3,714
1,877
3,394
3,398
3,015
5,597
4,494
2,181
2,484
1,869
4,399
3,351
1,968
1,410
2,148
4,810
2,029
3,629
11,320
3,370
4,067
5,472
1.559
3,703
3,127
3,162
1,044
8,829
58,316
10,353
4,350
6,142
3,088
3,210
730
860
960
748
1,207
641
382
1,384
7.495
1,369
1,177
648
258
959
1,419
1,713
3,516
3,012
1,390
3,570
2,400
3.253
1,249
2,548
3,015
1,987
4 353
3,378
1,168
1,823
1,542
3,228
1,942
1,609
185
527
650
650
734
934
844
1,744
1,322
830
803
441
1,071
866
595
490
572
1.916
706
872
6,024
1,114
931
1,381
418
1,127
627
1,299
327
4.002
39,221
4.961
1,559
1,449
638
935
541
962
1,842
2,870
1,320
2,545
6,884
2,298
2,940
4,261
1,107
1.927
2,622
2,176
751
6,666
36,516
5,636
2,648
4,963
2,366
2,314
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
743a
SC101805 Appeal Document Number 39 Page 4
744a
Stipulated Exhibit 18
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
SC101805 Appeal Document Number 40 Page 1
https://www.newspapers.com/image-view/389167837/
Copyright © 2025 Newspapers.com. All Rights Reserved.
The Butler Times-Press (Butler, Missouri) · Thu, Feb 16, 1922 · Page 1
Downloaded on Nov 7, 2025
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
745a
SC101805 Appeal Document Number 40 Page 2
https://www.newspapers.com/image-view/1024732326/
Copyright © 2025 Newspapers.com. All Rights Reserved.
The Kansas City Post (Kansas City, Missouri) · Fri, Oct 27, 1922 · Page 5
Downloaded on Nov 7, 2025
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
746a
SC101805 Appeal Document Number 40 Page 3
https://www.newspapers.com/image-view/166712764/
Copyright © 2025 Newspapers.com. All Rights Reserved.
The Houston Herald (Houston, Missouri) · Thu, Nov 2, 1922 · Page 3
Downloaded on Nov 7, 2025
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
747a
SC101805 Appeal Document Number 40 Page 4
748a
Stipulated Exhibit 19
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
SC101805 Appeal Document Number 41 Page 1
https://www.newspapers.com/image/649816811/
The Kansas City Star (Kansas City, Missouri) · Thu, Jan 24, 1952 · Page
24
Downloaded on Aug 10, 2026
Clipped By:
nathan_elwood
Aug 10, 2026
Copyright © 2026 Newspapers.com. All Rights Reserved.
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
749a
SC101805 Appeal Document Number 41 Page 2
750a
https://www.newspapers.com/image/692649382/
Copyright © 2026 Newspapers.com. All Rights Reserved.
The Springfield News-Leader (Springfield, Missouri) · Sun, Feb 3, 1952 ·
Page 20
Downloaded on Aug 10, 2026
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
SC101805 Appeal Document Number 41 Page 3
https://www.newspapers.com/image/1029189541/
Copyright © 2026 Newspapers.com. All Rights Reserved.
Hannibal Courier-Post (Hannibal, Missouri) · Wed, Jun 25, 1952 · Page 8
Downloaded on Aug 10, 2026
Electronically Filed - COLE CIRCUIT - August 18, 2026 - 10:09 AM
751a
SC101805 Appeal Document Number 41 Page 4