Missouri Roundtable For Life, et al. v. Carnahan, et al., No. 10-3368 (8th Cir. 2012)
Annotate this CaseIn citizen initiatives, Roundtable submitted thirteen proposed constitutional amendments to the Missouri secretary of state. The statutory process required state officers to prepare a summary statement, fiscal note summary, and fiscal note for each proposed constitutional amendment. Roundtable alleged in a 42 U.S.C. 1983 action that the summaries prepared by the secretary of state and the state auditor "continuously and persistently stymied and frustrated" its intended messages in violation of its constitutional rights and Missouri statute 116.334. The court held that Roundtable lacked standing to raise its First Amendment challenges and its action involved uncertain or contingent future events not yet ripe for judicial review. On the merits, Roundtable's First Amendment claim failed because, inter alia, it had not shown any restriction on its ability to circulate petitions or otherwise engage in political speech. The court further held that the district court did not err in dismissing Roundtable's due process claims and the district court did not abuse its discretion in dismissing Roundtable's state law claims. Accordingly, the court affirmed the judgment of the district court.
Court Description: Civil Case - Civil Rights. District court's dismissal of claims that secretary of state and state auditor violated First Amendment and due process rights by their summary statements and financial summaries to proposed citizen initiatives for proposed constitutional amendments is affirmed. Roundtable objected to the summaries provided but did not pursue the ballot initiatives. Roundtable lacked standing to raise First Amendment claim because it failed to show cognizable injury, either harm to its reputation or criminal prosecution, or suppression of its speech. On the merits of the First Amendment claim, the Missouri ballot initiative law doe not limit the exchange of ideas during the petition circulation process and Roundtree did not show that it was limited in its ability to speak Roundtree did not make out a procedural due process claim because it did not show the state's review procedures were inadequate or unconstitutional; it did not show conduct shocking the conscience to support a substantive due process claim. District court did not abuse its discretion in declining to exercise supplemental jurisdiction over state law claims.
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