Megan Cowden v. United States Department of the Treasury
This text of Megan Cowden v. United States Department of the Treasury (Megan Cowden v. United States Department of the Treasury) is published on Counsel Stack Legal Research, covering Court of Appeals for the Eighth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.
Opinion
United States Court of Appeals For the Eighth Circuit ___________________________
No. 25-3174 ___________________________
Megan H. Cowden
Plaintiff - Appellant
v.
United States Department of the Treasury; Internal Revenue Service; United States of America
Defendants - Appellees ____________
Appeal from United States District Court for the Eastern District of Missouri - St. Louis ____________
Submitted: June 4, 2026 Filed: June 9, 2026 [Unpublished] ____________
Before BENTON, GRASZ, and STRAS, Circuit Judges. ____________ PER CURIAM.
Megan Cowden appeals the district court’s 1 dismissal of her civil action challenging a federal tax lien. Having jurisdiction under 28 U.S.C. § 1291, this court affirms the judgment as modified.
Upon careful review, this court agrees with the district court that it lacked jurisdiction. See Great Rivers Habitat All. v. Fed. Emergency Mgmt. Agency, 615 F.3d 985, 988 (8th Cir. 2010) (standard of review); Porter v. Fox, 99 F.3d 271, 274 (8th Cir. 1996) (per curiam). However, the judgment is modified to reflect that the dismissal is without prejudice. See MSK EyEs Ltd. v. Wells Fargo Bank, 546 F.3d 533, 539 n.3 (8th Cir. 2008) (courts are generally barred from dismissing with prejudice if subject matter jurisdiction is lacking).
The judgment is affirmed as modified. See 8th Cir. R. 47B. ______________________________
1 The Honorable Zachary M. Bluestone, United States District Judge for the Eastern District of Missouri.
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