Background
La Belle Dairy, LLC leased thousands of acres of forage land in Missouri from Sharpe Holdings, Inc. and the Charles N. Sharpe, Jr. Foundation to grow food for its cattle and manage waste. When Sharpe terminated an underlying agreement and later refused to sell additional land as required by the lease, La Belle Dairy sued for breach of contract. The district court granted a preliminary injunction preventing Sharpe from evicting the dairy or interfering with its possession, which Sharpe appealed.
The court’s reasoning
The Eighth Circuit first established jurisdiction, ruling that the district court order was a preliminary injunction in substance because it exceeded the twenty-eight-day limit for temporary restraining orders and was open-ended. The court held that Sharpe waived its due process claim by not objecting to the hearing’s scope in the lower court. On the merits, the court applied the standard for preliminary injunctions, finding La Belle Dairy had a fair chance of succeeding on its breach of contract claims. The court reasoned that the land-sale provision was enforceable under Missouri law because it provided a method for determining price and identifying the land. Additionally, the court found that the threat of eviction constituted irreparable harm that outweighed any minimal injury to Sharpe.
We think the order here, despite its label, has the practical effect of granting an injunction, and so we have jurisdiction to review it.
La Belle Dairy, LLC v. Sharpe Holdings, Inc., 25-1803 (8th Cir. July 23, 2026)
What it means going forward
The decision reinforces that appellate courts will look to the practical effect of orders rather than their labels to determine jurisdiction. It also clarifies that parties must raise due process objections regarding notice and hearings at the district court level to preserve them for appeal.