Missouri’s 19th judicial court finds that House Bill 2062, passed by the Missouri General Assembly in 2024, violates the Missouri Constitution’s Single Subject, Clear Title, and Original Purpose provisions. (Article III, Sections 21 and 23.)

Missourians added those clauses to their Constitution in the 1800’s to enhance transparency in the legislative process and to prevent “log-rolling,” the practice of combining bills that, on their own, would not garner enough support to become law. The Missouri legislature routinely ignores those constitutional limitations on their power.

Judge Stumpe also found that HB 2062 violated the Missouri and United States Contract Clauses, which forbid the passage of any law “impairing the obligation of contracts” between private parties.

The lawsuit was filed on behalf of Four Season’s Lakesites Property Owners Association Inc, a Missouri nonprofit corporation in good standing and registered with the Missouri Secretary of State.

Judge Brian Stumpe found 2024 HB 2062 to be unconstitutional on all counts. The Missouri Constitution Article III, Sections 21 & 23 clearly spells out how a bill is to become law.  Those provisions include a clear title, a single subject, and the original purpose of a bill must not be changed.  HB 2062 violated all 3 of these principles as it was amended throughout the legislative process including replacing the entire bill’s language with a substitute bill. 

The bill started out relating to moratoriums on eviction proceedings, and it ended up including everything from business licenses to electric vehicles, and even deed restrictions dealing with the ownership or pasturing of chickens.

Senator Mike Moon had voted against the bill and filed a constitutional letter of objection at the time of the bill signing.  Judge Stumpe referenced Senator Moon’s points in his written judgement. 

There are a handful of other similar challenges to bills passed in 2024 and 2025, including two that the Article III Institute is financially facilitating.

Article 3 was added to the 1945 Missouri Constitution to insure transparency in the process of making new laws based on many abuses of power by prior legislative bodies. 

The lawsuit case number is 24AC-CC07532

Updates will be posted on the Article 3 Institute website:  https://article3institute.org/

The Article 3 Institute is a non-profit public interest corporation whose purpose is to educate law makers on the provisions of Article 3 and to hold them accountable for violations via litigation.