Ronald J. Calzone and C. Michael Moon Missouri Cases

Ronald Calzone and Michael Moon sought a declaratory judgment and injunction to prevent the Secretary of State from placing a ballot measure, H.B. 1460, on the November 2018 general election ballot, arguing it was unconstitutional due to procedural infirmities. The circuit court entered judgment on the pleadings for the Secretary of State, finding the case ripe. On appeal, the Western District determined that the case was not ripe for pre-election judicial review because the challenges were substantive, not procedural, and the measure might not be enacted by voters. Consequently, the court dismissed the petition without prejudice, issuing the judgment the trial court should have entered.