Jonathan Allen Kobes

How Judge Kobes rules, drawn from 97 signed orders. Every observation links to the order it came from.

Court
U.S. Court of Appeals for the Eighth Circuit
Position
Circuit judge
Appointed by
Donald Trump (Republican)
Commissioned
December 12, 2018
ABA rating
Not Qualified
Education
Dordt University (B.A., 1996); Harvard Law School (J.D., 2000)
Signed orders read
97

About Judge Kobes

Jonathan Allen Kobes is a judge of the United States Court of Appeals for the Eighth Circuit. Appointed by President Donald J. Trump, Judge Kobes received a commission on December 12, 2018.

Judge Kobes's practices and standing orders

The court's website lists no individual practices or standing orders of Judge Kobes's own (checked October 11, 2026), so the court's local rules and general orders are the place to look (court page ↗).

Standing orders for every case in this court

Orders the court applies to all of its cases, whichever judge has them, as published on the court's website (checked October 11, 2026).

Key rules from these orders · The court's local rules ↗

How Judge Kobes decides

Patterns drawn from this judge's own signed orders. Every observation links to the order it came from.

What persuades

A narrowed class definition did not end American Pipe tolling unless it unambiguously excluded the plaintiff; genuine ambiguity was resolved in favor of preserving the individual claim.

“We join our sister circuits in holding that ‘anything short of unambiguous narrowing would undermine the balance contemplated by the Supreme Court’ in American Pipe and is insufficient to exclude a plaintiff from a class for tolling purposes.”

A criminal defendant's waiver of counsel required a meaningful warning about the risks of self-representation; merely calling the choice a bad decision was inadequate.

“While we do not have ‘a list of essential points’ or ‘specific warnings’ about self-representation, Tschacher, 687 F.3d at 932 (citations omitted), the district court must still ‘adequately warn[] the defendant about the dangers and disadvantages of proceeding pro se,’ United States v. Crawford, 487 F.3d 1101, 1106 (8th Cir. 2007). That did not happen here.”

In Gossett v. Jason’s Deli, he required a pregnancy-accommodation request to make clear that the employee sought assistance for the condition.

“The plaintiff need not use ‘the magic words “reasonable accommodation,”’ but the request ‘must make clear that the employee wants assistance for her [pregnancy].’”

In McDougall, Kobes held that the design-defect plaintiff had presented neither safer-design evidence nor a claim that the product should be removed from the market.

“But it is still the plaintiff’s burden to either present alternative design evidence or assert that the product is so unreasonably dangerous it should be removed from the market altogether.”

In Fraase v. Advantage Credit Bureau, he found the bureau reasonably relied on an official court-record site absent notice that the source was unreliable.

“Advantage reasonably believed that the official website for the North Dakota Courts was a reputable source.”

Procedural preferences

An application to confirm or vacate an arbitration award must plead its own independent basis for federal jurisdiction; the underlying dispute or an earlier action cannot supply a missing citizenship allegation.

“Applicants seeking to vacate or confirm awards under § 9 and § 10 must identify an ‘independent jurisdictional basis’ for their actions.”

A civil-contempt sanction imposed while the underlying claims remained pending was not immediately appealable because the district court still had substantive work to do.

“The district court has more to do; in fact, it hasn’t had the opportunity to adjudicate Nolting’s liability on any claim made directly against him.”

In Colson v. Hennepin County, he found the complaint did not connect the employee’s objection to workplace testing with her stated religious beliefs.

“The problem is that her complaint fails to connect her objections to the County’s testing policy with her specific religious beliefs.”

Under de novo benefits review, the district court may consider the full evidentiary record rather than confining itself to the plan administrator's stated rationale.

“because the standard of review was de novo, the district court was ‘not limited to the fiduciary’s explanation of its denial.’”

In Murphy, Kobes separately concurred in the judgment on an attorney-fee award. He found an error in the lodestar calculation but agreed it did not require reversal because the appellant had suggested the shortcut used below.

“Appellees conceded that not all their hours were reasonably expended, so the district court should have reduced the hours in its lodestar calculation.”

Cautions

For qualified immunity, a broad statement of constitutional principle did not clearly establish liability without precedent addressing materially similar circumstances.

“But this general principle is too broad to clearly establish a constitutional violation here.”

Adverse inferences cannot substitute for missing proof of an essential causal link. Even assuming withheld evidence could support an inference at summary judgment, the proposed inferences did not connect the alleged racketeering acts directly to collection of the judgments.

“None of the adverse inferences the employees asked it to draw would have filled the ‘gaps’ in their causation evidence.”

In United States v. Burns, Kobes reviewed an equal-protection argument raised for the first time on appeal only for plain error and affirmed denial of suppression.

“Because Burns failed to make this argument below, we review for plain error.”

In Fechner, Kobes concurred in the judgment but found error in admitting images unrelated to the charged material.

“The district court erred by admitting non-pornographic images of children found on the SD card.”

In International Union, Kobes dissented because he viewed the arbitration award as final and the later challenge as untimely.

“The June Award is the final award, and because the Union filed its case more that 90 days later it is untimely.”

Signed rulings

A grounded sample of orders signed by this judge, with the verbatim dispositive language.

Alexis Bailly Vineyard, Inc. v. John Harrington
18-1846 · 2019-07-29
Appeal (appellant) Granted

“We reverse the district court's order granting summary judgment and remand for further proceedings.”

Winfred Beasley v. Warren Unilube, Inc.
18-2655 · 2019-08-09
Appeal (appellant) Denied

“The district court granted Warren's motion for summary judgment. We affirm.”

United States v. Michael Lowry
18-3109 · 2019-08-30
Appeal (appellant) Denied

“Although we agree that the officer who stopped Lowry lacked reasonable suspicion, suppression of the evidence is inappropriate under the attenuation doctrine. We therefore affirm.”

William Anderson v. City of Minneapolis
18-1941 · 2019-08-20
Appeal (appellant) Denied

“The district court granted defendants' motions to dismiss with prejudice. Anderson appeals the dismissal of his constitutional claims, and we affirm.”

Adam and Eve Jonesboro, LLC v. Harold Perrin
18-2818 · 2019-08-12
Appeal (appellant) Denied

“We hold that Adam and Eve has not engaged in speech and therefore cannot state a claim under the First Amendment. We also hold that the zoning law is not unconstitutionally vague and does not violate equal protection. We affirm.”

Brandon Peterson v. Cmdr. Roger Heinen
22-1603 · 2023-12-26
Appeal (appellant) Granted in part

“we reverse in part, dismiss in part, and vacate in part. The case is remanded to the district court.”

United States v. Frank Vanoy
18-3165 · 2020-04-27
Appeal (appellant) Denied

“Vanoy's sentence is affirmed.”

United States v. Randy Dabney
21-2111 · 2022-08-03
Appeal (appellant) Denied

“We affirm.”

United States v. Christopher Stowell
21-2234 · 2022-07-25
Appeal (appellant) Denied

“We affirm.”

United States v. Mark Eggerson
19-3742 · 2021-06-07
Appeal (appellant) Denied

“We affirm.”

United States v. Christopher Martin
20-1511 · 2021-10-18
Appeal (appellant) Denied

“We affirm the district court's career offender enhancement. ... The judgment of the district court is affirmed.”

United States v. Tevin Maurstad
20-2936 · 2022-06-03
Appeal (appellant) Denied

“We affirm.”

Caseload & timing

From public federal docket records for this judge.

Circuit judges do not carry a trial caseload; not enumerated.

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