The Supreme Court of Missouri on Tuesday unanimously upheld Governor Mike Kehoe’s authority to call a 2025 extraordinary legislative session focused on congressional redistricting and changes to Missouri’s initiative petition process, rejecting a challenge brought by the Missouri NAACP.

In a 9-page opinion authored by Judge Mary Russell, the court affirmed a Cole County Circuit Court ruling that found the governor acted within his constitutional authority under Article IV, Section 9 of the Missouri Constitution when he convened the Second Extraordinary Session of the 103rd General Assembly.

The lawsuit was brought by the National Association for the Advancement of Colored People Missouri State Conference, along with plaintiffs Patricia Jones and Traci Wilson-Kleekamp, who argued the Missouri Constitution requires a truly “extraordinary” circumstance before a governor can call lawmakers back into session. The plaintiffs contended the issues cited by Kehoe — congressional redistricting and initiative petition reform — did not meet that threshold because lawmakers were already aware of them during the regular legislative session.

The court rejected that argument, holding that the constitution gives the governor broad discretion to determine when an extraordinary occasion exists.

“The plain language of article IV, section 9 gives the governor discretion to determine when an extraordinary occasion has arisen and to call an extraordinary session,” the opinion stated.

Kehoe’s August 2025 proclamation cited concerns over Missouri’s congressional map potentially facing legal challenges under the Voting Rights Act and the Fourteenth Amendment, the approaching 2026 candidate filing deadline, and the need for changes to the initiative petition process.

Lawmakers ultimately used the special session to pass House Bill 1, which established a new congressional map, and House Joint Resolution 3, a proposed constitutional amendment altering Missouri’s initiative petition process.

Writing for the unanimous court, Russell said the constitution’s repeated use of the phrase “deem necessary” demonstrates the governor is entrusted with determining when legislative action is warranted.

The opinion also rejected the NAACP’s interpretation that “extraordinary” required an unusual or unforeseen crisis, instead concluding the term simply refers to a session occurring outside the legislature’s ordinary schedule.

“Contrary to NAACP’s contention, article IV, section 9 of the Missouri Constitution does not include language suggesting the governor’s discretion to call an extraordinary session is limited in any way,” the court wrote.

Because the court determined the governor acted within his constitutional authority, it declined to address the lower court’s additional finding that the lawsuit presented a nonjusticiable political question.

The ruling marks another major legal victory for the Kehoe administration surrounding the special session and the resulting congressional redistricting law, which has already been the subject of multiple court battles and referendum litigation ahead of the 2026 election cycle.