Agred Foundation v. U.S. Army Corps of Engineers, No. 20-2102 (8th Cir. 2021)
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AGRED filed suit seeking a declaratory judgment regarding its rights and obligations under a written agreement with the United States. The Corps, acting on behalf of the United States, moved to dismiss for lack of subject matter jurisdiction on the grounds that AGRED lacks standing.
The Eighth Circuit affirmed the district court's dismissal of AGRED's declaratory judgment claim based on lack of subject matter jurisdiction and agreed with the district court that AGRED's injury was not caused by the Corps. In this case, AGRED failed to establish a connection between its injury of being enjoined from charging fees for access a lake plaintiff owns and the Corps' conduct. The court explained that there are several kinks in AGRED's causal chain, including that AGRED's injury results directly from FOLEA's thus far successful lawsuit. In this case, there is no real contractual dispute between AGRED and the Corps. Therefore, AGRED fails to meet the causation requirement for standing because it cannot show that its injury is fairly traceable to the Corps.
Court Description: [Smith, Author, with Wollman and Stras, Circuit Judges] Civil case - Civil procedure. The district court did not err in dismissing the declaratory judgment action against the Corps for lack of standing because plaintiff could not establish a connection between its injury (being enjoined from charging fees for access a lake plaintiff owns) and any conduct on the Corps' part;the state court injunction prohibiting plaintiff from collecting the fees results directly from a suit by lake users and not from the Corps' refusal to take a position on whether plaintiff could collect fees under the agreement between the Corps and plaintiff's predecessor-in-interest.
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