Megan H. Cowden v. United States Department of the Treasury

United States Court of Appeals
For the Eighth Circuit
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No. 25-3174
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Megan H. Cowden
Plaintiff - Appellant
v.
United States Department of the Treasury; Internal Revenue Service;
United States of America
Defendants - Appellees
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Appeal from United States District Court
for the Eastern District of Missouri - St. Louis
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Submitted: June 4, 2026
Filed: June 9, 2026
[Unpublished]
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Before BENTON, GRASZ, and STRAS, Circuit Judges.
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PER CURIAM.
Megan Cowden appeals the district court’s1 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.
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1 The Honorable Zachary M. Bluestone, United States District Judge for the
Eastern District of Missouri.

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