The U.S. Court of Appeals for the Eighth Circuit affirmed the dismissal of a pro se lawsuit filed against President Donald Trump and two federal agencies, ruling that the plaintiff failed to establish standing to sue.
In an unpublished opinion filed Jan. 27, a three-judge panel consisting of Circuit Judges BENTON, STRAS, and KOBES affirmed the U.S. District Court for the Western District of Missouri's dismissal of the case brought by Darrell Leon McClanahan, III, a Missouri resident.
McClanahan sued President Trump in his official capacity, the U.S. Department of Justice, and the U.S. Department of Education as defendants. The case was originally heard in the district court in Joplin, Missouri, before Judge M. Douglas Harpool.
The district court dismissed McClanahan's pro se complaint for lack of standing, finding that the plaintiff had not sufficiently alleged facts showing he suffered an injury caused by the defendants. The court also denied McClanahan's request for leave to amend his complaint.
On appeal, the Eighth Circuit conducted a careful review of the lower court's ruling and concluded that the district court committed no error in its dismissal or in denying leave to amend. The appeals court cited established precedent governing standards of review for such dismissals.
The court referenced *Gelschus v. Hogen*, 47 F.4th 679, 686 (8th Cir. 2022), and *U.S. ex rel. Raynor v. Nat'l Rural Utils. Coop. Fin., Corp.*, 690 F.3d 951, 957 (8th Cir. 2012), as controlling authority for the standard of review applied to the case.
According to the opinion, McClanahan failed to allege sufficient facts to make plausible that he suffered an injury that the defendants caused. This failure to establish the foundational elements of standing - injury in fact, causation, and redressability - proved fatal to his claims.
Standing doctrine requires plaintiffs to demonstrate they have suffered a concrete and particularized injury that is fairly traceable to the defendant's conduct and likely to be redressed by a favorable judicial decision. Without these elements, federal courts lack subject matter jurisdiction to hear a case.
The Eighth Circuit's decision represents a straightforward application of established standing requirements in federal court. Pro se litigants, who represent themselves without counsel, often struggle with the technical requirements of federal civil procedure and constitutional limitations on federal court jurisdiction.
The case was submitted to the appeals court on Jan. 21, 2026, and decided within a week, suggesting the court found the standing deficiencies clear enough to warrant prompt resolution. The unpublished nature of the opinion indicates the court viewed the matter as routine application of established law rather than presenting novel legal questions.
While the specific nature of McClanahan's claims against the Trump administration and federal agencies remains unclear from the available court documents, the procedural dismissal suggests the complaint failed to meet basic federal court requirements regardless of the underlying merits.
The case highlights the challenges facing pro se litigants in federal court, where technical pleading requirements and jurisdictional limitations can prove difficult to navigate without legal training. Federal courts have limited ability to assist pro se plaintiffs in curing defective pleadings, particularly when fundamental jurisdictional requirements like standing are not met.
The Eighth Circuit's jurisdiction encompasses appeals from federal district courts in Arkansas, Iowa, Minnesota, Missouri, Nebraska, North Dakota, and South Dakota. The court regularly handles appeals involving challenges to federal agency actions and suits against federal officials.
With the Trump administration having taken office recently, federal courts across the country are likely to see an uptick in litigation challenging various administration policies and actions. However, as this case demonstrates, all such suits must still meet basic constitutional and procedural requirements to proceed in federal court.
The affirmance means McClanahan's case is concluded unless he seeks further review by the Supreme Court, though the Court accepts very few cases for review and rarely takes cases involving routine applications of standing doctrine.
This case serves as a reminder that federal courts maintain strict requirements for who may bring suit and under what circumstances, regardless of the political profile of the defendants involved. The standing doctrine continues to serve as a significant barrier to federal court access, particularly for plaintiffs proceeding without counsel.