## Facts

- The Missouri General Assembly enacted Senate Bill 5 (2015) to reform municipal governance and municipal courts, including limits on municipal fine-and-fee revenue and new compliance obligations.
- Section 479.359.2 reduced a statewide cap on municipal revenue from ordinance-violation fines, forfeitures, and court costs from 30% to 20%, but imposed a stricter 12.5% cap for a county with a charter form of government and more than 950,000 inhabitants and its municipalities (a description that applied only to St. Louis County at the time).
- Section 67.287 imposed additional regulatory, reporting, and compliance requirements on municipalities and municipal courts, with sanctions for noncompliance.
- Section 479.359.3 provided enforcement mechanisms for the caps, including potential disincorporation proceedings for noncompliant municipalities.
- Twelve St. Louis County municipalities and two county taxpayers sued state officials for declaratory and injunctive relief, alleging violations of the Missouri Constitution, including the special-laws prohibition and the Hancock Amendment.
- The trial court held section 67.287 and the St. Louis County–specific portion of section 479.359.2 unconstitutional as special laws, found Hancock violations as to sections 67.287 and 479.359.3, permanently enjoined enforcement, and rejected plaintiffs’ other constitutional claims.
- The State appealed; plaintiffs cross-appealed on rejected constitutional theories.

## Issues

1. Whether section 67.287, and section 479.359.2 to the extent it created a 12.5% cap applicable only to St. Louis County and its municipalities, violated the Missouri Constitution’s prohibition on special laws (Mo. Const. art. III, § 40(30)).
2. Whether sections 67.287 and 479.359.3 imposed unfunded mandates in violation of the Hancock Amendment (Mo. Const. art. X, §§ 16, 21).
3. Whether SB 5 violated other state constitutional provisions asserted by plaintiffs.

## Decision

- Affirmed that section 67.287 is an unconstitutional special law.
- Affirmed that the St. Louis County–specific 12.5% proviso in section 479.359.2 is an unconstitutional special law.
- Severed the 12.5% proviso from section 479.359.2, leaving a uniform statewide 20% cap in effect.
- Reversed the trial court’s Hancock rulings as to sections 67.287 and 479.359.3, holding the claims unripe and the alleged increased duties de minimis.
- Affirmed rejection of plaintiffs’ remaining constitutional claims.

## Legal Principles

- A statute that, in operation, targets a single political subdivision may be invalid as a “special law” under Mo. Const. art. III, § 40(30).
- When challenged special legislation is defended in court, the State must present evidence of “substantial justification” for the narrow classification; absent such evidence, the law violates the special-laws prohibition.
- Invalid local or targeted language within an otherwise valid statute may be severed if the remainder can function independently and reflects a workable legislative scheme.
- Hancock Amendment claims for new or increased local governmental activities are not ripe when the constitutional period for state appropriation has not yet expired; minimal added duties do not establish a Hancock violation.

## Conclusion

The Missouri Supreme Court held that SB 5 provisions singling out St. Louis County municipalities lacked evidentiary justification and therefore constituted unconstitutional special laws, but preserved the statewide fine-and-fee cap by severing only the local proviso; it also rejected unfunded-mandate claims as unripe and de minimis while affirming dismissal of other constitutional challenges.


City of Normandy v. Greitens, 518 S.W.3d 183 (Mo. 2017)