# Butler v. Watson **338 So. 3d 599 (Miss. 2021), No. 2020-IA-01199-SCT, decided 14 May 2021.** The Mississippi Supreme Court voided Initiative 65, the medical-marijuana measure voters had approved in November 2020, and with it the state's entire ballot-initiative process. The holding turned on arithmetic rather than on anything about the measure. Art. 15, § 273(3) of the Mississippi Constitution provides that the signatures from any one congressional district "shall not exceed one-fifth (1/5) of the total number of signatures required," and that any excess "shall not be considered by the Secretary of State." The section was written in 1992, when Mississippi had five congressional districts. It has had four since the 2000 census, so the maximum a sponsor can lawfully assemble is four fifths of the requirement. The court held that § 273(3) "disables itself in being unworkable with fewer than five congressional districts," and that only the people, by constitutional amendment, could repair it. Mississippi has had no usable initiative process since. Restoration requires a legislative referral, and attempts failed in 2022, 2023, 2024, 2025 and 2026; the 2026 vehicle, SCR 518, was tabled in the Senate on 11 February 2026 on an unrecorded voice vote with no companion in the House. The state filed no initiative petitions at all for the 2026 cycle. Stage 0 of [[How a Ballot Measure Gets on the Ballot]] draws this as the one place where a reserved power exists in constitutional text and cannot be exercised.