The underlying dispute centers on La Belle Dairy’s rights to purchase approximately 6,100 acres of farmland leased from Sharpe Holdings. La Belle purchased the dairy operation from Sharpe in 2017 and subsequently entered into a lease agreement that required the sale of the adjacent land. La Belle alleges Sharpe refused to sell the property in accordance with the lease terms, prompting Armstrong to file suit on La Belle’s behalf in January 2025.
Sharpe Holdings argued that Armstrong had a conflict of interest because it previously represented Sharpe in 2015 and 2016 regarding Occupational Safety and Health Administration regulatory violations at the dairy. Sharpe contended that because Armstrong had not returned a $25,000 retainer until November 2025, the firm remained its current client. Alternatively, Sharpe argued that the OSHA matter was substantially related to the current land dispute, prohibiting Armstrong from representing La Belle under Missouri professional conduct rules.
Judge Autrey focused primarily on the timeliness of Sharpe’s objection, applying Eighth Circuit precedent that disqualification motions must be brought with reasonable promptness. The court noted that Sharpe did not file its motion until January 23, 2026, nearly twelve months after Armstrong filed the original complaint.
The court rejected Sharpe’s argument that it only discovered the conflict in September 2025 when an appellee brief listed Armstrong attorneys. Judge Autrey found it improbable that Sharpe’s General Counsel, David R. Melton, failed to notice Armstrong’s role as counsel of record during months of active litigation, which included a temporary restraining order hearing, discovery disputes, and mediation.
Furthermore, the court held that Sharpe’s retained outside counsel knew of Armstrong’s representation in January 2025, and that knowledge is imputed to the company. Even accepting Sharpe’s claim of later discovery, the court found a three-month delay in raising the issue with opposing counsel and an additional four-and-a-half months before filing the motion to be unreasonable.
Judge Autrey also emphasized the prejudice La Belle would suffer if disqualification were granted at this late stage. Armstrong had already secured a temporary restraining order, briefed an appeal in the Eighth Circuit, served discovery, and participated in mediation. The court noted that Sharpe had not raised the conflict issue before the Eighth Circuit, where Armstrong also appeared as appellate counsel.
Because Sharpe waived its right to assert the conflict through unreasonable delay, the court declined to address whether an actual conflict existed. The motion to disqualify was denied.