Supreme Court of Missouri
State of Missouri ex rel. Dr. Anna Fitz-James v. Andrew Bailey
July 20, 2023
Summary
The Supreme Court of Missouri affirmed the Cole County circuit court’s permanent writ of mandamus ordering Attorney General Andrew Bailey to approve the fiscal note summaries prepared by the State Auditor and to notify the Auditor of that approval. The Court held that the Attorney General’s statutory authority is limited to reviewing the legal content and form of the summaries, that this duty is ministerial, and that mandamus is the proper remedy. The decision rests on a plain‑meaning construction of section 116.175 of the Revised Statutes of Missouri. The Court also rejected the Attorney General’s substantive challenges to the fiscal notes.