In the fall of 2014 Missouri voters approved a constitutional amendment placing a right-to-farm provision in the state constitution. The plaintiffs brought a post-election challenge to the ballot title summary statement. While the court said that the challenge was permissible, the court also held that the ballot title was sufficient and fair and did not need to refer to article VI of the state constitution which governs local governments. The "right to farm" being "forever guaranteed" did not mean that the right would be unlimited or completely free from regulation. A dissent would have disallowed the challenge in its entirety as impermissible "sandbagging." Shoemyer, et al. v. Kander, No. SC94516, 2015 Mo. LEXIS 100 (Mo. Sup. Ct. Jun. 30, 2015).