Case Explained: Jane Doe v. Anoka County; James Stuart, the Anoka County Sheriff

Court: United States Court of Appeals for the Eighth Circuit Filed: 2026-08-10 The eighth-circuit vacated the district court’s judgment on the plaintiff’s federal constitutional claims and remanded with instructions to dismiss them for lack of standing under Article III of the Constitution. Relying on Supreme Court precedent in *Linda R.S. v. Richard D.* and Eighth Circuit decisions in *Parkhurst v. Tabor* and *Pratt v. Helms*, the court held that crime victims lack standing to assert equal protection or failure-to-investigate claims against law enforcement officials under 42 U.S.C. § 1983, even when alleging class-based discrimination based on sex. The court reasoned that private citizens have no constitutional right to an investigation of a crime committed against them and that police decisions concerning investigations are inherently discretionary and ill-suited to judicial second-guessing. Because the plaintiff lacked standing to assert her federal claims, the court declined to address the defendants’ immunity arguments. The court remanded the plaintiff’s state law intentional infliction of emotional distress claim to the district court to determine whether she has standing to assert that specific claim, as the parties did not address whether the federal standing analysis applies to state law causes of action. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.