Humane Society of the United States v. State
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In 1992, Mo. Rev. Stat. 273.327 was enacted, requiring persons engaged in commercial animal care to obtain a license and exempted pounds and animal shelters from paying annual licensing and per-capita fees. In 2010, the General Assembly passed S.B. 795, which repealed and reenacted section 273.327. The reenacted version of section 273.327 eliminated animal shelters from the entities exempt from the payment of fees. In 2011, the General Assembly passed S.B. 161, which repealed and reenacted section 273.327 and cured any procedural defects in the passage of S.B. 795. The Humane Society subsequently filed a petition for declaratory judgment and injunctive relief, asserting that the amended version of section 273.327 was unconstitutional because S.B. 795 was amended during its passage to change its original purpose. The trial court granted summary judgment for the State, concluding that the Humane Society's cause of action was moot as a result of the General Assembly's repeal and reenactment of section 273.327 in S.B. 161.
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