Matthew Kezhaya v. City of Belle Plaine, 78 F.4th 1045

The Satanic Temple sued the City of Belle Plaine asserting constitutional and state-law claims; nine constitutional counts were dismissed without prejudice and promissory estoppel remained.
After the district court’s deadline to amend, the Temple sought leave to amend to reassert dismissed constitutional claims and add new ones; a magistrate judge denied leave as untimely and futile and rejected a proposal to dismiss the promissory-estoppel claim and refile the constitutional claims later.
Instead of appealing, counsel (Matthew Kezhaya) filed a second lawsuit reasserting the rejected constitutional claims based on the same core facts; the City moved to dismiss as duplicative and sought Rule 11 sanctions.
The district court dismissed the second suit as duplicative, found the filing frivolous and in disregard of court orders, and awarded the City $16,943.40 in Rule 11 attorney’s fees (reduced 50% from the requested amount).
Kezhaya appealed, arguing the second suit was permissible because earlier dismissals were "without prejudice," that sanctions were inappropriate or should have been non-monetary, and that the fee award/amount was erroneous given insurance and lack of detailed findings.
The Eighth Circuit affirmed, holding the second suit was duplicative, Rule 11 sanctions were appropriate to deter repetition, and the fee award and reduction were within the district court’s discretion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the second suit was barred as duplicative/res judicata	"Without prejudice" dismissal permitted refiling; needed second suit to litigate	Second suit relied on the same nucleus of facts; claims were available earlier and should have been appealed	Dismissal affirmed: second suit duplicative; plaintiff had full and fair opportunity to litigate in first action
Whether Rule 11 sanctions were proper	Legal error or an unpersuasive argument is not sanctionable; counsel reasonably relied on precedent	Filing was improper, vexatious, and wasted resources; aimed to evade magistrate’s ruling	Sanctions proper under Rule 11 for presenting frivolous/duplicative litigation to harass/increase costs
Whether a non-monetary sanction (reprimand) would suffice	A reprimand would deter and be adequate	Monetary sanction needed to deter repeated disregard of court orders	Monetary sanction warranted given waste of resources and prior warnings
Whether fee award/amount was improper (insurance, lack of detail)	City didn’t "incur" fees if insurance pays; district failed to sufficiently justify amount	Fees were "incurred" when billed; court examined rates and reduced request by 50% for duplication	Award of $16,943.40 affirmed; district court reasonably found rates acceptable and properly reduced duplicative charges

Cooter & Gell v. Hartmarx Corp., 496 U.S. 384 (1990) (abuse-of-discretion standard for Rule 11 review; fact-intensive determinations deserve deference)
Curtis v. Citibank, N.A., 226 F.3d 133 (2d Cir. 2000) (rule against maintaining two actions on same subject; duplicative litigation doctrine)
Scholz v. United States, 18 F.4th 941 (7th Cir. 2021) (same-nucleus-of-operative-fact test for duplicative suits)
Poe v. John Deere Co., 695 F.2d 1103 (8th Cir. 1982) (requiring timely assertion of claims; later refiling not permitted when claims were available earlier)
Kulinski v. Medtronic Bio-Medicus, Inc., 112 F.3d 368 (8th Cir. 1997) (distinguishable: refiling permitted where initial dismissal was for lack of jurisdiction rather than a merits futility ruling)
SFM Holdings, Ltd. v. Banc of Am. Secs., LLC, 764 F.3d 1327 (11th Cir. 2014) (denial of leave to amend as futile is a merits ruling)