Yesterday, the Missouri Supreme Court issued a ruling striking down Missouri House Bill 1606 (2022), particularly section 67.2300, which sought to criminalize unauthorized sleeping and camping on state-owned lands, making it a class C misdemeanor. The Court found this section to be in violation of the Missouri Constitution’s single subject requirement.
In the decision, the Supreme Court emphasized that the inclusion of section 67.2300 introduced an impermissible additional subject—homelessness—into the bill, which was originally focused on political subdivisions. Justice Paul C. Wilson, writing for the Court, noted that the provisions of section 67.2300 “do not fairly relate to or have a natural connection with” the subject of political subdivisions, and instead relate to the different subject of homelessness. This divergence from the bill’s original purpose led to the conclusion that TAFP HB 1606, in its entirety, violated the single subject requirement of article III section 23 of the Missouri Constitution.