Supreme Court of Missouri / Dec 19, 2023
Johnathan Byrd, et al., The Gathering Tree D/B/A Eden Village v. State of MO, et al.
Appellants Johnathan Byrd, et al., and The Gathering Tree d/b/a Eden Village challenged the constitutional validity of House Bill 1606, arguing it violated the single subject, clear title, and original purpose requirements of the Missouri Constitution. The circuit court rejected these challenges and granted judgment on the pleadings for the State of Missouri. The Missouri Supreme Court reversed, holding that HB 1606 violated the single subject rule by including provisions on homelessness that were not germane to its stated subject of "political subdivisions." The Court further determined that the unconstitutional portions could not be severed, rendering the entire bill invalid.