Scott Meyer v. Gayla Rahn, et al.

Whether the grant of the motion to dismiss was an abuse of discretion, not based upon the undisputed facts presented, and supported by only the erroneous application of the relevant law.

Whether the district court’s conclusion that the Plaintiff s complaint failed to state a claim upon which relief could be granted was an abuse of discretion, not supported by the facts presented, and a misapplication of the relevant law. See Ashcroft v. Iqbal, 556 U.S. 662 (2009); Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007); Federer v. Gephardt, 363 F.3d 754, 757 (8th Cir. 2004); Rucci v. City of Pacific, 321 F.3d 651, 652 (8th Cir. 2003); Scheuer v. Rhodes, 416 U.S. 232 (1974).

Whether the district court’s conclusion that Plaintiffs complaint was barred due to sovereign immunity as the plaintiff continues to be denied the ability to purchase a firearm. Thus there is an ongoing violation of federal law and the plaintiff is seeking prospective relief, an Ex Parte exception to the sovereign immunity defense. See Ex Parte Young, 209 U.S. 123 (1908); Kodiak Oil & Gas (USA) Inc. v. Burr, 932 F.3d 1125, 1131-32 (8th Cir. 2019); McDaniel v. Neal, 44 F.4th 1085, 1089 (8th Cir. 2022). Pennhurst State School & Hospital v. Halderman, 465 U.S. 89 (1984). Will v. Michigan Dept, of State Police, 491 U.S. 58 (1989).

Whether the district court’s conclusion that the plaintiffs complaint against defendants in their per­ sonal capacities was barred by quasi-judicial immunity. See Doe v. Chapman, 30 F.4th 766 (8th Cir. 2022); Boyer v. County of Washington, 971 F.2d 100, 102 (8th Cir. 1992); Forrester v. White, 484 U.S. 219 (1988);