Cormack v. Settle-Beshears
United States Court of Appeals for the Eighth Circuit
474 F.3d 528 (2007)
After the City of Van Buren annexed Cormack's (plaintiff's) property and banned fireworks sales there, leading police to forcibly close his fireworks business, Cormack appealed his resulting conviction to state court and separately sued the city, its attorney, and two officers in federal court alleging Takings Clause, Due Process, and Fourth Amendment violations; the district court dismissed his federal claims for failure to show state remedies were unavailable or inadequate.
Whether a federal court will dismiss a plaintiff's civil rights claim against state or local officials until state remedies are exhausted or shown to be unavailable or inadequate to redress the alleged grievance.