Janice Duffner v. City of St. Peters, Missouri, 930 F.3d 973

Janice and Carl Duffner bought a St. Peters, Missouri, home and converted the yard into a flower/ornamental garden.
The City adopted an ordinance requiring at least 50% of a residential yard to be turf grass; violations carried daily misdemeanor penalties (fine and/or jail).
City notified the Duffners of noncompliance in 2014; a variance required 5% turf grass, which they declined to meet.
The Duffners sued in Missouri state court asserting substantive due process and state-law claims; the court dismissed for failure to state a claim as to the federal substantive due process theory on alternative grounds; the Duffners unsuccessfully sought to amend and voluntarily dismissed remaining claims.
The Duffners then filed in federal district court raising substantive due process and an Eighth Amendment excessive-fines challenge; the district court granted summary judgment to the City on both federal claims on the merits and declined supplemental jurisdiction over state claims.
On appeal, the Eighth Circuit affirms dismissal of the substantive due process claim as barred by res judicata and holds the Eighth Amendment excessive-fines claim is not ripe, remanding with instructions to dismiss that claim for lack of jurisdiction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether substantive due process challenge to turf-grass ordinance can proceed	Duffner: ordinance is irrational and violates substantive due process; federal complaint added new facts supporting irrationality	City: claim already litigated/dismissed in state court and is precluded by res judicata	Court: barred by res judicata — federal claim substantially repeats state petition dismissed for failure to state a claim
Whether Eighth Amendment excessive-fines claim is ripe	Duffner: penalty provision is unconstitutional regardless of whether fines have yet been imposed	City: claim is not ripe because no fines/sanctions have been assessed	Court: not ripe; dismissal for lack of jurisdiction is required because no penalties have been imposed and the issue would benefit from further factual development

C.H. Robinson Worldwide, Inc. v. Lobrano, 695 F.3d 758 (8th Cir.) (apply law of forum that rendered first judgment for res judicata analysis)
Woodworth v. Hulshof, 891 F.3d 1083 (8th Cir.) (appellate review of district court grant of summary judgment is de novo)
Nat’l Park Hosp. Ass’n v. Dep’t of Interior, 538 U.S. 803 (U.S. Sup. Ct.) (ripeness framework: fitness and hardship)
United States v. Williams, 128 F.3d 1239 (8th Cir.) (Eighth Amendment challenges not ripe absent imposition or imminent imposition of punishment)
Cheffer v. Reno, 55 F.3d 1517 (11th Cir.) (Eighth Amendment challenges generally not ripe until fine or punishment is imposed or imminent)
Iowa League of Cities v. EPA, 711 F.3d 844 (8th Cir.) (agency action benefits from further factual development before judicial resolution)
Pub. Water Supply Dist. No. 10 v. City of Peculiar, 345 F.3d 570 (8th Cir.) (ripeness analysis and prudential considerations)