Andrew Bailey, in his Official Capacity as Attorney General of Missouri, and Ken Zellers, in his Official Capacity as Commissioner of the Office of Administration Missouri Cases

The Conservation Commission and Missouri Department of Conservation sought declaratory relief against the Attorney General and Commissioner of the Office of Administration after the General Assembly attempted to restrict the Commission's use of appropriated funds for land acquisition and payments in lieu of taxes (PILT). The circuit court ruled in favor of the Commission, finding the General Assembly lacked authority to limit the Commission's constitutional powers. The Missouri Supreme Court affirmed, holding that Article IV, sections 40-44 grant the Conservation Commission plenary authority to expend and use conservation funds for constitutionally enumerated purposes, and the General Assembly cannot interfere with this authority.