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Missouri civic engagement organizations strike down voter registration and absentee ballot solicitation limitations

The League of Women Voters of Missouri (“LWVMO”) and the Missouri State Conference of the NAACP (the “MONAACP”) successfully challenged four provisions of HB 1878 (2022), “each [which] makes it more difficult for non-partisan, non-profit civic organizations such as Plaintiffs to engage in voter outreach and activities they undertake to spread their pro-voter message and increase participation in elections.” League of Women Voters of Missouri, Final Order and Judgment, Page 2.


The four challenged provisions are: 1) the ban on compensation for soliciting voter registration applications (codified in Section 115.205.1 RSMo.); 2) the requirement that any unpaid individual who solicits more than 10 voter registration applications register with the Secretary of State as a “voter registration solicitor” (codified in Section 115.205.1 RSMo.); 3) the requirement that any voter registration solicitor be a registered Missouri voter of at least 18 years of age (codified in Section 115.205.1 RSMo.); and 4) that “no individual, group, or party shall solicit a voter into obtaining an absentee ballot application.” Section 115.205.2 RSMo. These provisions have been enjoined since October 2022 and unless appealed will be permanently enjoined. The Circuit Court determined that the challenged provisions violated LWVMO and MONAACP’s members’ rights to speech, expression, association, and due process, as they burdened core political speech and expressive conduct relating to the voting process. Therefore, the Circuit Court ruled that the challenged provisions failed under any level of scrutiny in the Missouri Constitution.

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