☰ Revisor of Missouri


Effective - 27 Feb 1945, see footnote    bottom

  III Section 23.  Limitation of scope of bills — contents of titles — exceptions. — No bill shall contain more than one subject which shall be clearly expressed in its title, except bills enacted under the third exception in section 37 of this article and general appropriation bills, which may embrace the various subjects and accounts for which moneys are appropriated.


Source: Const. of 1875, Art. IV, § 28.

(1954) Land Clearance for Redevelopment Law (RSMo, § 99.300 et seq.) in providing for the clearance of blighted and insanitary areas and also for the redevelopment of areas which have been cleared, does not contain more than one subject. State on Inf. Dalton v. Land Clearance for Redev. Auth., 364 Mo. 974, 270 S.W.2d 44.

(1956) Title reading "An act to make uniform the law of warehouse receipts" held broad enough to embrace not only the substantive law as to relation of warehouseman and depositor but also the procedural law whereby their rights are to be determined. Brown v. Sloan's Moving & Storage Co. (Mo.), 296 S.W.2d 20.

(1957) Title reading "An Act to make uniform the law of warehouse receipts" held sufficient to include provision of law imposing upon warehouseman burden of establishing excuse for failure or refusal to deliver goods when demanded. Hoerath v. Sloan's Mvg. & Storage Co. (Mo.), 305 S.W.2d 418.

(1959) An act amending the act providing for the organizaiton of levee districts so as to authorize such districts to cooperate with the federal government in securing and constructing reclamation projects held germane to the original title of the act and consequently not in violation of this provision of the constitution. In re Tarkio-Squaw Levee Dist. of Holt County (Mo.), 319 S.W.2d 660.

(1959) Title of act reenacting section fixing and limiting fees and commissions of county collectors which stated that it was to repeal and reenact section of chapter entitled collectors and collection of taxes, held sufficient although as reenacted section contained provision making limits applicable to ex officio collectors. State v. Ludwig (Mo.), 322 S.W.2d 841.

(1960) The title of an act is essentially a part of the act and is itself a legislative expression of the general scope of a bill and it may be looked to as an aid in arriving at the intent of the legislation. In re Tompkins' Estate (Mo.), 341 S.W.2d 866.

(1962) Provision vesting jurisdiction of appeals from the lower court in cases involving the termination of minimum wages on public works held not within a title reading "an act regulating wages of laborers, mechanics and other workmen employed in the construction of public works." United Brotherhood of Carpenters and Joiners of America v. Industrial Commission (Mo.), 352 S.W.2d 633.

(1962) Section authorizing board of school district to lease or sell to institution of higher education property not required for use of school district and which could be used for purposes of offering education beyond grade twelve, contained in act "to provide for the formation of junior college districts and to establish the powers and duties of the state board of education with respect thereto", held to be unconstitutional and violative of this section. State ex rel. Normandy School Dist. of St. Louis County v. Small (Mo.), 356 S.W.2d 864.

(1962) Validity of section 556.280 upheld against charge that title of act violated provisions of this constitutional provision. Title read "An act to repeal section 556.280, RSMo 1949, relating to second and subsequent offenses, and to enact in lieu thereof a new section relating to the same subject and to the trial and punishment of persons convicted of crime following one or more convictions, to be known as section 556.280." State v. Weindorf (Mo.), 361 S.W.2d 806.

(1975) Held that title of bill which used language "industrial development of blighted, insanitary or underdeveloped industrial areas" was not unconstitutional for failure to clearly express its subject because the bill contained provisions relating to financing and to powers of cities and other public bodies in relation to such functions. State ex rel. Atkinson v. Planned Industrial Expansion Authority (Mo.), 517 S.W.2d 36.

(1975) Held that bill creating office of medical examiner and abolishing office of coroner did not contain two subjects. State ex rel. McClellan v. Godfrey (Mo.), 519 S.W.2d 4.

(1975) Held that original purpose was not changed by amendment and that title did clearly express the purpose of senate bill 253 of the second regular session of the 77th general assembly. State ex rel. Toedebusch Transfer, Inc. v. Public Service Commission (Mo.), 520 S.W.2d 38.

(1984) Title to a bill needs only to indicate general content and amendments need only be germane to the general area indicated by title. Westin Crown Plaza Hotel v. King, 664 S.W.2d 2 (Mo. en banc 1984).

(1994) Section 2 of H.C.S. for H.B.s 551 and 552 enacted by 87th General Assembly (sections 66.700 to 66.710, RSMo) declared unconstitutional because it violates procedural requirement of section. Bill was found to contain more than one subject. Section was severed from bill and declared void. Hammerschmidt v. Boone County, 877 S.W.2d 98 (Mo. en banc).

(1997) "Relating to economic development" is an overly broad subject matter for a bill. Carmack v. Director, Missouri Department of Agriculture, 945 S.W.2d 956 (Mo.banc 1997).

---- end of effective  27 Feb 1945 ----

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