169-2025: INITIATIVES.INITIATIVE PETITIONS.

ATTORNEY GENERAL OF MISSOURI
ANDREW BAILEY
Supreme Court Building
207 W. High Street
P.O. Box 899
Jefferson City, MO 65102
Phone: (573) 751-3321
Fax: (573) 751-0774
www.ago.mo.gov
August 1, 2025
OPINION LETTER NO. 169-2025
The Honorable Scott Fitzpatrick
Missouri State Auditor
Truman State Office Building, Room 880
Jefferson City, MO 65101
Dear Auditor Fitzpatrick:
This office received your letter of July 23, 2025, submitting a fiscal note and
fiscal note summary prepared under § 116.175, RSMo, for an initiative petition
submitted by Spencer Toder, 2026-070. The fiscal note summary that you
submitted is as follows:
Southeast Missouri State University estimates an unknown fiscal impact.
The Attorney General's Office estimates annual increased operating costs of
at least $427,516 and unknown costs to the Legal Expense Fund that could
exceed $1 million. Other state governmental entities estimate no costs or
savings. Local governmental entities estimate no costs or savings.
Under § 116.175.4, RSMo, we approve the legal content and form of the fiscal
note summary. Because our review of the fiscal note summary is mandated by
statute, no action that we take with respect to such review should be construed as
an endorsement of the initiative petition or as the expression of any view regarding
the objectives of its proponents. Furthermore, our review under § 116.175.4 does not
examine the fairness or sufficiency of the estimated fiscal impact.
Very truly yours,
ANDREW BAILEY
Attorney General
OP-2025-181