Section 2.15 Extra Services and Services Pertaining to Other Offices

• Library: Local Government Deskbook (2017 Ed.)

B. (§2.15) Extra Services and Services Pertaining to Other Offices

While article VII, § 13, of the Missouri Constitution generally prohibits midterm increases in compensation for state, county, and municipal officers, this prohibition is not absolute. See State ex rel. George v. Verkamp, 365 S.W.3d 598, 601 (Mo. banc 2012). To the contrary, the Supreme Court of Missouri has recognized that additional compensation may be merited when “‘additional duties, extrinsic or not germane to the office, have been imposed in conjunction with the increase in compensation.’” Id. (quoting Laclede Cnty. v. Douglass, 43 S.W.3d 826, 828 (Mo. banc 2001)).

Recall that the purpose of article VII, § 13, is to prohibit persons of prestige or influence of official power from using that power to their own personal advantage. Yet, when an incumbent is asked to perform new duties not germane (i.e., foreign) to their office, it cannot be said that article...