State of Missouri, et al., Respondents/Cross- Missouri Cases

Sean Soendker Nicholson sued the State of Missouri, challenging the constitutionality of Senate Bill No. 22, alleging violations of the original purpose, single subject, and clear title provisions of the Missouri Constitution. The circuit court found SB 22 constitutional regarding these procedural limitations but unconstitutional on equal protection grounds for one section, which it severed. On appeal, the Missouri Supreme Court reversed, holding that SB 22 violated the original purpose requirement because an amendment granting the attorney general new appeal powers was not germane to the bill's original purpose concerning ballot summaries. The Court further found the offending provision could not be severed, thus invalidating SB 22 in its entirety.