dissenting.
The majority holds that the title of SB 60 is unconstitutional because it is underinelu-sive in that it is entitled “an act ... relating to solid waste management,” but fails to reflect that provisions of the bill also deal with hazardous waste management. The majority treats “relating to” as language of exclusivity, thereby restricting the reach of SB 60 to provisions dealing solely with solid waste management. I disagree because this restrictive reading of the title is contrary to the plain meaning of the words “relating to”; the majority’s interpretation conflicts with our precedent instructing that only language that clearly and undoubtedly violates the procedural limitation will support a constitutional challenge; and no showing has been made on the record that hazardous waste management is, in fact, unrelated to solid waste management.
*823The title of SB 60 expressly states the subject of the act to be “relating to solid waste management.” The majority contends that the language “relating to” is a restrictive term and, therefore, it prohibits the inclusion of a provision dealing with hazardous waste. They hold that “the phrase ‘relating to solid waste management,’ ... implies that the bill does not relate to any other kind of waste management.” This reading contradicts the plain and ordinary meaning of the words “relating to.” These are words of connection not restriction. “Relate” is defined as “to show or establish a logical or causal connection between.” “Related” is defined as “connected by reason of an established or discoverable relation.” Webster’s International 1916 (3d ed.1981).
The common use of these words in the legislative process has been to indicate in a title that matters connected with the stated subject of the bill may be indicated therein. Otherwise, if each matter touched upon by a bill must be separately stated in the bill’s title, the title would need to recite almost the entirety of the bill itself. Thus, the proper analysis should begin by determining if there is a logical or causal connection between hazardous and solid waste management. The majority fails to demonstrate that such a relationship is lacking other than to say, in a conclusory statement, that “relating to” excludes other types of waste management.
The majority’s novel1 reading of “relating to” as a restrictive term, and their subsequent finding that the title is “underinclu-sive,” is contrary to the reasoning of our past decisions. In Hammerschmidt v. Boone County, we found that a bill whose subject was to amend laws “relating to elections” violated the single subject requirement of article III, sec. 28 when it included a provision that permitted a county to adopt its own constitution. 877 S.W.2d 98 (Mo.1994). Never relying on a restrictive reading of “relating to,” we instead emphasized that the challenged provision “does not fairly relate to elections, nor does it have a natural connection to that subject.” Id. at 103. Further, we recognized the following principles, stating:
[A]n act of the legislature approved by the governor carries with it a strong presumption of constitutionality. This Court will resolve doubts in favor of the procedural and substantive validity of an act of the legislature. Attacks against legislative action founded on constitutionally imposed procedural limitations are not favored; we ascribe to the General Assembly the same good and praiseworthy motivations as inform our decision-making processes. Therefore, this Court interprets procedural limitations liberally and will uphold the constitutionality of a statute against such an attack unless the act dearly and undoubtedly violates the constitutional limita-tion_ [T]his Court has consistently attempted to avoid an interpretation of the Constitution that will “limit or cripple legislative enactments any further than what was necessary by the absolute requirements of the law.” Id. at 102 (citations omitted) (emphasis added).
In Fust v. Attorney General for the State of Missouri, 947 S.W.2d 424 (Mo.1997), a provision granting fifty percent of any punitive damages award to the state was challenged as not being clearly expressed in a title reading “to repeal ... and to enact ... new sections for the purpose of assuring just compensation for certain person’s damages.” Among appellant’s arguments was that the title was too restrictive to encompass the “punitive damages” provision. We rejected those contentions, holding that “appellants have failed to sustain their burden of establishing that the title contains a restriction or limitation_” Id. at 429. We noted that “the one asserting the unconstitutionality of the statute has the burden of showing the constitutional procedural limitation has ‘clearly and undoubtedly’ been contravened.” Id. at 428. (citation omitted). Most significantly, we stated “the title need not describe every detail contained in the bill. The title to the act is valid if it indicates the general contents of the act_” Id. at 429 (emphasis added).
In Stroh Brewery Co. v. State, 954 S.W.2d 323 (Mo.1997), we analyzed the original title *824of SB 938, which read “an act to amend ... by adding one new section relating to the auction of vintage wine....” Undertaking an original purpose analysis, we faced the issue of whether the term [‘by’] restricted the manner in which the bill could be amended. We stated that “while [by] might have been meant to convey exclusivity, such a construction is not clear and undoubtedly so. When alternative readings of a statute are possible, we must choose the reading that is constitutional.” Id. We noted that the legislature could have used clearer language of limitation — such as “for the sole purpose of.” We also recognized that:
“[A] bill’s sponsor is faced with a double-edged strategic choice. A title that is broadly worded as to purpose will accommodate many amendments that may garner sufficient support for the bill’s passage. Alternatively, a title that is more limited as to purpose may protect the bill from undesired amendments, but may lessen the ability of the bill to garner sufficient support for passage. Because we are required to uphold the constitutionality of a statute against attack unless the statute clearly and undoubtedly violates the constitution, only clear and undoubted language limiting purpose will support an article III, section 21 challenge.”
Id. at 326.
Particularly fatal to the majority’s analysis is the fact it entirely overlooks the record below and the failure of respondent to establish as a matter of fact what solid waste management and hazardous waste management are, or that they are, in fact, not related. See State v. Hampton, 653 S.W.2d 191, 194 (Mo. banc 1983) (“The burden of establishing [a statute’s] unconstitutionality rests upon the party questioning it.”) Instead, the majority appears willing simply to declare that solid waste management and hazardous waste management are not related as a matter of law, despite the fact that neither are defined in the statute or have been defined by our prior case law.
Admittedly, the terms “solid waste” and “hazardous waste” are defined by the statute and it is true that the definition affirms that they are not one in the same. The definition does not say, however, that the two are unrelated to one another.
A review of the law surrounding hazardous and solid waste reveals that the two are related. Our legislature has defined solid waste, as shown above, as including “garbage, refuse and other discarded materials....” Section 260.200(34), RSMo 1996 Supp. Hazardous waste is defined as:
“[A]ny waste or combination of wastes, as determined by the commission by rules and regulations, which, because of its quantity, concentration, or physical, chemical or infectious characteristics, may cause or significantly contribute to an increase in mortality or an increase in serious irreversible, or incapacitating reversible, illness, or pose a present or potential threat to the health of humans or the environment.”
Section 260.360(11), RSMo 1996 Supp. Simply put, both topics relate to waste. Whether hazardous or solid, our legislature has set up schemes to transport, discard, and dispose of it. It is telling that the legislature defined “solid waste” as excluding hazardous waste. Such a distinction would be unnecessary if the two subjects were unrelated to one another.
A look at federal environmental law also demonstrates the close relationship between hazardous and solid waste. The federal Resource Conservation and Recovery Act regulations define “Hazardous waste as a subset of ‘solid waste’ with characteristics that pose hazards to human health or the environment.” William Rodgers Jr., Environmental Law, Section 7.8 (1992). “Hazardous waste is a specifically regulated subcategory of waste, in which certain characteristics are met by a discarded material.” James T. O’Reilly, State & Local Government Solid Waste Management, Section 1.01, n. 2 (citing 42 U.S.C. Section 6921) (1994). What is solid waste and what is hazardous waste, at times, may be a difficult distinction to make. “Waste can slip in and out of the ‘hazardous’ category ...” Rodgers, at Section 7.8. “The criteria for identifying a ‘hazardous waste’ have undergone episodic fits and starts ...” Id. “The stakes are high in these definitional disputes (refugees from the category of ‘haz*825ardous waste’ under Subtitle C often reappear as ‘solid waste’ under Subtitle D, where regulation is much milder) ...” Id.
Although there are critical distinctions between solid and hazardous waste, these distinctions do not break the relationship between the two categories of waste. For the majority’s reliance on the definition of solid waste to be relevant, there must be language of exclusivity restricting the reach of SB 60 to only solid waste, which is lacking.
Were it our duty to draft the best possible titles for legislation, then I could understand the majority’s hesitation to embrace this title. However, that is not our duty. Our duty is to strike down statutes only when the language “clearly and undoubtedly” violates the constitutional limitation. The majority’s decision that “relating to solid waste management” implies that the bill does not relate to any other kind of waste is not a' plain and ordinary reading of the phrase “relating to.” Further, this new construction, when read with our previous opinions addressing these issues, will merely serve to confuse and frustrate the General Assembly as it tries to ascertain just what it is the constitution requires of them.
The majority also appears to criticize the legislature because this amendment was “tacked onto the tail end” of Senate Bill 60 two days before the end of the session. Again, it is not our duty to prescribe procedures for the legislature not already set out in the constitution. This fact is legally irrelevant and we overstep our bounds in making this criticism.
For these reasons, I respectfully dissent.
. Respondent did not even raise or argue such a proposition.