Enterprise Financial Group Inc. v. Podhorn, No. 18-1591 (8th Cir. 2019)
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The absence of a judgment in the state court litigation does not mean that plaintiff lacks Article III standing to bring this suit. Enterprise filed suit against several defendants, alleging a claim under the Missouri Uniform Fraudulent Transfer Act. The district court dismissed the complaint without prejudice based on the ground that there was no case or controversy because Enterprise lacked Article III standing.
The Eighth Circuit reversed and held that Enterprise has alleged facts sufficient to demonstrate the elements of standing. In this case, Enterprise has sufficiently alleged a present injury in fact, fairly traceable to defendants, as the transferees of the funds. Therefore, the court remanded for further proceedings.
Court Description: Colloton, Author, with Smith, Chief Judge, and Erickson, Circuit Judges] Civil case - Missouri Uniform Fraudulent Transfer Act. Plaintiff alleged defendants had received transfers from NAVISS, a company it was suing in Texas state court for damages and a declaration that it had a security interest in NAVISS's assets; defendants moved to dismiss this federal action for lack of standing, arguing there was not a case or controversy in light of the absence of a judgment in the still-pending Texas action which would establish NAVISS had breached its agreements with plaintiff or owed it anything; held, the absence of a judgment in the state court litigation does not mean that plaintiff lacks Article III standing to bring this suit; plaintiff has sufficiently alleged a present injury in fact, fairly traceable to defendants, as the transferees of the funds; dismissal for lack of standing reversed and the case remanded for further proceedings.
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