In 1980, Missouri voters adopted an amendment to the Missouri Constitution. The amendment, commonly called the Hancock Amendment, limited the power of state and local governments to raise taxes by requiring voter approval for tax increases and by Placing a spending limit on the state government. One of the controversial issues has been whether fees charged for governmental services may be raised without a vote. Initially, the Missouri Supreme Court, employing the plain meaning rule, held that such fees could not be raised without voter consent. Keller v. Marion County Ambulance District, the subject of this Note, marks a welcome change of that position, and a more rational approach to constitutional construction.

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