ACI Plastics v. City of St. Louis

In ACI Plastics v. City of St. Louis, 724 S.W.2d 513 (Mo. banc 1987), the Court struck down a St. Louis ordinance that put to the voters a question that included two unrelated revenue raising measures, a gross receipts tax of 3/8 of one percent on all sales in the City and a five dollar monthly fee per employee imposed on all employers in the City. The title of the enactment (which essentially repeated the body of the proposal) did not suggest, any more than the bill itself did, any common subject to which each of these facially unrelated provisions might apply.