Have you ever intently followed legislation that you supported—an education bill, for instance—only to find out that another education-related proposal you didn’t like had been added to the bill as an amendment. While this can be frustrating to the observing citizen, it certainly is not unusual and most often is appropriate under the Missouri state constitution. That was the subject of the Missouri Supreme Court’s recent combined opinion in Calzone v. Interim Commnr. of Dep’t of Elem. & Secondary Educ. and Calzone v. Director of Dep’t of Agric., issued October 1, 2019.
Applicable Constitutional Provisions
The Missouri state constitution prevents
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