Case 0001
Article 3 Institute v. State of Missouri
Case Synopsis and Files
CASE NUMBER: 24AC-CC08732
Senate Bill 754 (Luetkemeyer) was prefiled on December 1, 2023 as a five page bill with a title that said it was "relating to law enforcement animals."
It ended up as 69 page "Senate Substitute 2 for Senate Committee Substitute for SENATE BILLS NOS. 754, 746, 788, 765, 841, 887 & 861," "relating to public safety."
While it could be argued that the purpose of SB 754 had changed through the legislative process in violation of Article III, Section 21 of the Missouri Constitution, and that the final version included more than one subject in violation of Article III, Section 23, this case only alleges the requirement that each bill's title clearly express its core subject has been violated.
The title "public safety" could be applied to most of the functions of government. The obvious application might be law enforcement, but it could also apply to the courts, health care matters, transportation infrastructure, labor and industrial relations, defense, and even education, among other things.
As recently as January 30, 2024, the Missouri Supreme Court agreed in a unanimous opinion that "relating to public safety" was not a constitutional bill title.
This Court has previously found phrases such as “public safety” are too broad and amorphous to describe the subject of a pending bill with the precision necessary to provide notice of its contents.
- City of St. Louis v. State of Missouri with respect to SB 26 (2021)
It stands to reason that to be consistent the courts will also have to find the exact same phrase lacking in the present lawsuit.
Plaintiff Documents
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