U.S. Court of Appeals for the Eighth Circuit, 2025

Joe Meyer v. United States

Joe Meyer v. United States
U.S. Court of Appeals for the Eighth Circuit · Decided July 23, 2025

Joe Meyer v. United States

Opinion

United States Court of Appeals For the Eighth Circuit ___________________________ No. 24-3331 ___________________________ Joe Meyer lllllllllllllllllllllPlaintiff - Appellant v. United States of America lllllllllllllllllllllDefendant - Appellee ____________ Appeal from United States District Court for the Northern District of Iowa - Western ____________ Submitted: July 18, 2025 Filed: July 23, 2025 [Unpublished] ____________ Before LOKEN, GRUENDER, and GRASZ, Circuit Judges. ____________ PER CURIAM.

Iowa resident Joe Meyer brought this tax refund action against the United States to recover disallowed net operating losses he carried forward to subsequent tax years and claimed as an Earned Income Tax Credit (EITC), plus damages based on what he would have earned had he timely received the claimed EITC credit.

The district court1 denied Meyer’s pro se motion for summary judgment, ruling in a lengthy Order on Cross Motions for Summary Judgment that Meyer “does not clearly set forth the statutory vehicles for his claims for relief” and “fails to comply with Local Rule 56;” that his EITC refund claim is based on “his misguided interpretation of [26 U.S.C.] § 32” and fails because he did not demonstrate earned income in the subsequent tax year, which is required to be eligible for an EITC credit; and that his damage claim for lost business and investment opportunities is barred by his failure to show government conduct that is actionable under 26 U.S.C. § 7433.

The district court dismissed the case and Meyer timely appealed. After careful review, we affirm for the reasons stated by the district court. See 8th Cir. R. 47B; Johnson v. Blaukat, 453 F.3d 1108, 1112 (8th Cir. 2006) (standard of review). ______________________________

The Honorable Leonard T. Strand, United States District Judge for the Northern District of Iowa. -2-

Case-law data current through December 31, 2025. Source: CourtListener bulk data.