Case Explained: Matthew Goforth, an individual; Malinda Goforth, an individual; MG Management Co., LLC, a Missouri Limited Liability Company; Malinda’s Sugar and Spice LLC, a Missouri Limited Liability Company v. Transform Holdco, LLC, a Delaware limited liability company; Hometown Midco LLC, a Delaware limited liability company; ESL Investments, Inc., a Delaware corporation; ESL Partners, L.P., a Delaware limited partnership

Court: United States Court of Appeals for the Eighth Circuit Filed: 2026-07-28 The eighth-circuit affirmed the district court’s grant of summary judgment in favor of the defendants, holding that the plaintiffs’ federal antitrust claims were compulsory counterclaims that should have been raised in the initial arbitration proceeding. The court applied Federal Rule of Civil Procedure 13(a), which requires a party to assert any claim arising out of the same transaction or occurrence as the opposing party’s claim. The court determined that the antitrust cause of action accrued when Sears initiated the first arbitration to enforce the non-compete provision, as this filing constituted an overt act giving rise to the claim under established antitrust accrual principles. Consequently, the plaintiffs were required to bring their counterclaims during that initial proceeding rather than initiating a separate arbitration or lawsuit later. The court also rejected the argument that Malinda Goforth was exempt from this requirement because she was not a signatory to the original agreement, noting that the agreement explicitly extended its terms and arbitration provisions to spouses, and she could have asserted jurisdictional objections while simultaneously filing a compulsory counterclaim. As a result of the affirmation, the plaintiffs’ antitrust claims against the defendants are barred. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.