Americans deserve to know if their elected leaders are passing laws that affect their lives, which is exactly why Missouri has a constitutional requirement that each bill in the state legislature must have a “clear title.” But over the years, the General Assembly has adopted ever-broader bill titles that do not meaningfully tell the public what issues are addressed in the bills. This week, the Goldwater Institute is heading to the Missouri Supreme Court to ensure that lawmakers properly inform citizens about what’s in the bills they are considering.
In Article III Institute v. State of Missouri, the Goldwater Institute is challenging the constitutionality of Senate Bill 754, a massive, 69-page “public safety” bill the legislature passed in 2024. The bill packed together more than two dozen unrelated provisions under the vague, catch-all umbrella title “relating to public safety.” This is precisely the type of bill title Missouri’s constitution prohibits—the “Clear Title” requirement states that “no bill shall contain more than one subject which shall be clearly expressed in its title.”
Just two years ago the Missouri Supreme Court suggested that “public safety” is a topic too broad and amorphous to comply with the Clear Title requirement – but it did not resolve that issue because the parties had not raised it. This case directly presents that question, providing a critical test of the lengths to which the state legislature may go in obscuring the substance of a bill.
Oral arguments will take place on Wednesday at the Missouri Supreme Court Building in Jefferson City. The court’s session begins at 9 a.m., with arguments in the Article III Institute case scheduled second on the docket. This will be the ninth state supreme court in which Goldwater attorneys have stood up for individual rights and government transparency and accountability.
Dave Roland, Goldwater’s Director of Allied Litigation, will argue the case on behalf of Missouri taxpayers and constitutional accountability. This will be Roland’s ninth Missouri Supreme Court appearance and his first since joining Goldwater in January.
“The people of Missouri placed strict procedural limits on the General Assembly to prevent logrolling, stealth legislation, and multi-subject grab bags,” Roland said. “When lawmakers use amorphous titles like ‘public safety,’ citizens can only guess as to what the bill actually contains. This deprives citizens of their constitutional right to monitor and participate in the legislative process. We are asking the Supreme Court to uphold the constitution and enforce the limits Missourians placed on their government.”
The Goldwater Institute and the Article III Institute—a Missouri nonprofit focused on legislative accountability—pursued this case because constitutional limitations on government are only useful if someone is willing to fight to see those limitations enforced. Simply put, Missourians deserve transparency when it comes to the bills the General Assembly considers and passes.
