Megan Cowden v. United States Department of the Treasury

United States Court of Appeals

For the Eighth Circuit ___________________________

No. 25-3174 ___________________________

Megan H. Cowden Plaintiff - Appellant v.

United States Department of the Treasury; Internal Revenue Service;

United States of America Defendants - Appellees ____________

Appeal from United States District Court for the Eastern District of Missouri - St. Louis ____________ Submitted: June 4, 2026 Filed: June 9, 2026 [Unpublished] ____________

Before BENTON, GRASZ, and STRAS, Circuit Judges.

____________ PER CURIAM.

Megan Cowden appeals the district court’s 1 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.