Ollin Star, LC v. Clemens Food Group, LLC

Opinion

United States Court of Appeals For the Eighth Circuit ___________________________

No. 25-2525 ___________________________

Ollin Star, LC

lllllllllllllllllllllPlaintiff - Appellant

v.

Clemens Food Group, LLC; Country View Family Farms, LLC

lllllllllllllllllllllDefendants - Appellees ____________

Appeal from United States District Court for the Southern District of Iowa - Central ____________

Submitted: June 17, 2026 Filed: June 23, 2026 [Unpublished] ____________

Before LOKEN, KELLY, and KOBES, Circuit Judges. ____________

PER CURIAM.

Iowa recruiting firm Ollin Star, LC appeals the district court’s1 adverse grant of summary judgment in its diversity breach-of-contract action. Upon de novo

1 The Honorable Rebecca Goodgame Ebinger, United States District Judge for the Southern District of Iowa. review, we affirm. See Ag Spectrum Co. v. Elder, 865 F.3d 1088, 1091 (8th Cir. 2017) (standard of review). We conclude that the parties’ non-compete covenant was unenforceable under Iowa law, for the reasons stated by the district court. See id. at 1092-93 (under Iowa law, non-compete provision between seller and independent contractor was not enforceable, as it was not reasonably necessary to protect seller’s business, it disproportionately burdened contractor, and public interest factor did not strongly support either side); Lamp v. Am. Prosthetics, Inc., 379 N.W.2d 909, 910 (Iowa 1986) (en banc) (factors in deciding whether to enforce restrictive covenant).

The judgment is affirmed. See 8th Cir. R. 47B. ______________________________

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