Missouri Republicans approved a new congressional map in 2025 that aims to unseat Democratic U.S. Rep. Emanuel Cleaver, prompting lawsuits and a possible statewide referendum. Supporters of the plan invoke an 'Air Bud'–style argument that the state constitution does not explicitly forbid mid-decade redistricting, while opponents hope courts or voters will overturn it.
In 2025, Missouri joined Texas in pursuing mid-decade congressional redistricting, after President Trump publicly urged Republican-led states to redraw maps to help maintain GOP control of the U.S. House ahead of the next midterm elections. Missouri lawmakers answered that call by passing a new congressional map designed to make U.S. Rep. Emanuel Cleaver's Kansas City–based seat more favorable to Republicans, according to reporting from NPR and St. Louis Public Radio.
The state Senate approved the plan in September 2025, sending it to Republican Gov. Mike Kehoe, who had unveiled the proposal and branded it a "Missouri First" map. The move departed from the usual practice of redrawing congressional lines only once per decade after the U.S. census.
Opponents swiftly filed lawsuits, arguing that Missouri's constitution ties congressional redistricting to the decennial census and does not authorize lawmakers to redo the map in the middle of the decade. Attorneys challenging the plan have asked courts for a clear ruling that the legislature lacks that mid-decade power.
Supporters of the map have countered with what has become known as the "Air Bud Rule," a reference to the 1997 Disney film in which a golden retriever is allowed to play basketball because, as a referee says, "ain't no rule says a dog can't play basketball." As reported by KCUR and other public radio outlets, some Missouri Republicans argue that because the state constitution does not expressly forbid mid-decade redistricting, lawmakers retain the authority to pass a new map.
Republican Secretary of State Denny Hoskins embraced the comparison, saying that "there's nothing, in my opinion, that says that we cannot do this" and joking that, if the courts uphold the map, it should be nicknamed the "Air Bud Clause." Democratic state Rep. Mark Boyko mocked the reasoning on the House floor, likening it to children insisting on ice cream immediately simply because a parent promised to go for ice cream the next day.
In court, plaintiffs' attorney Chuck Hatfield also seized on the movie analogy, contending that the state's defense effectively relies on an "Air Bud" reading of Missouri's charter. "We don't do Air Bud rules in Missouri for very good reason," he said, arguing that the absence of an explicit ban should not be read as a green light for mid-decade redistricting.
Missouri Attorney General Catherine Hanaway, who leads the state's legal defense, has said she has never seen the film but called the "ain't no rule" principle "not a bad analogy" for the state's position. She has argued that the constitution requires lawmakers to draw maps after the decennial census but does not specify that they may do so only once per decade or bar them from revisiting the lines.
Even if the courts ultimately uphold the map, it may still face a popular vote. Because the plan did not secure enough support in the Missouri House to take effect immediately, opponents can gather petition signatures to force a referendum and potentially block the new districts from being used in the next congressional election. St. Louis Public Radio reports that many Republican lawmakers, including state Rep. Bryant Wolfin, initially said they did not realize the map could be put to a statewide vote.
Organizers opposed to the map have been traveling the state to collect signatures to place the issue on the ballot. The campaign has energized Democrats who were dispirited after a difficult 2024 election cycle. "We need to stop the power grab. We don't need to do it every three years," Jefferson City resident Frida Tucker said in an interview, expressing frustration with repeated attempts to remake the congressional lines.
The fight over Missouri's congressional map has become a showcase for the state's direct democracy tools, including the referendum process, and for how a pop-culture reference can shape public debate over complex constitutional questions. With lawsuits moving forward and a petition drive underway, the ultimate fate of the map — and the Air Bud analogy — will likely be decided by a combination of judges and voters.
