Tricia Marie Myers v. Itasca County HRA; Diane Larson; Carrie Schmitz; Kenda Roddenberg
June 24, 2026·25-3122·Panel Decision·By Aisha Johnson
The Eighth Circuit affirmed a district court's grant of summary judgment in a civil rights action brought under Section nineteen eighty-three. The appellate court held that the district court properly relied on a declaration submitted by one of the defendants.
Tricia Myers filed a pro se action under Section nineteen eighty-three against Itasca County Human Resources Agency and three individual defendants. The district court granted summary judgment against Myers. Myers appealed the adverse ruling.
The court’s reasoning
The panel concluded that the district court permissibly relied on a declaration submitted by defendant Diane Larson. The court noted that under Federal Rule of Civil Procedure fifty-six, subsection C, paragraph four, an affidavit used to support summary judgment must be made on personal knowledge, set out facts admissible in evidence, and show the affiant is competent to testify. The court also affirmed that summary judgment was proper under the standard of review established in Lloyd versus FedLoan Servicing.
What it means going forward
The decision upholds the dismissal of the civil rights claim at the summary judgment stage, reinforcing the requirement that affidavits supporting such motions meet specific competency and knowledge standards.
