Calla M. Mears


Mike Kehoe was appointed to Lieutenant Governor of Missouri in 2018 after Michael Parson became Governor of Missouri following the resignation of Eric Greitens.1 A lawsuit raising interesting questions about the constitutional process for filling public office vacancies quickly followed the appointment of Lieutenant Governor Kehoe.2 Article IV, Section 4 of the Missouri Constitution states: “The governor shall fill all vacancies in public offices unless otherwise provided by law, and his appointees shall serve until their successors are duly elected or appointed and qualified.”3 First, what exactly does the phrase “unless otherwise provided by law” mean in the context of filling vacancies? Second, what are the legal implications of allowing the governor to appoint a lieutenant governor when Missouri law expressly disallows it? Finally, what are some other methods of filling vacancies that would be constitutional and more democratic?

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