The Eighth Circuit Court of Appeals recently ruled on a case involving Parker Stewart and his former business partner, Christopher Hamze, affirming the dismissal of Stewart's claims under the Racketeer Influenced and Corrupt Organizations Act (RICO). The ruling, filed on November 13, 2026, affects Stewart's ability to recover damages related to his former ownership in imINDY, a custom T-shirt company, and clarifies the legal capacity of shareholders to bring claims on behalf of their corporations.

This case matters because it addresses the rights of shareholders in business disputes, particularly regarding claims of fraud and mismanagement. The court's decision may influence how similar cases are handled in the future, especially in terms of shareholder rights and the legal definitions of capacity to sue.

Background

Parker Stewart and Christopher Hamze co-founded imINDY, LLC, which operated under the name TeeLaunch, in 2012. They entered into agreements that established their ownership stakes and management responsibilities. Stewart and Hamze each held a 50% share in the company after contributing $10,000 each. The Two Party Authorization Agreement (TPAA) required both partners to approve any disbursements from the company’s bank account.

In 2017, Stewart began out-patient medical treatment and alleges that he and Hamze verbally agreed that Hamze would manage the company’s day-to-day operations during Stewart's absence. However, Stewart claims he was not consulted on financial decisions and was denied access to the company’s financial records. This led to a decline in the company's sales and ultimately a buyout agreement in September 2023, where Stewart sold his 50% share for $550,000. After the sale, Stewart discovered suspicious financial activities that he claims would have affected his decision to sell.

In January 2025, Stewart filed a lawsuit against Plains Commerce Bank and several other defendants, alleging RICO violations and other claims related to the management of imINDY. The case was heard in the District Court for the District of South Dakota, which dismissed Stewart's claims and awarded attorney fees to the defendants.

The Ruling

The Eighth Circuit Court of Appeals, consisting of Judges Loken, Gruender, and Kelly, reviewed the case and upheld the lower court's decision. The court ruled that Stewart lacked the legal capacity to bring a RICO claim on behalf of imINDY because he was no longer a member of the company at the time he filed the lawsuit. According to the court, “Stewart lacked legal capacity to bring a derivative RICO claim on imINDY’s behalf.”

The court also addressed Stewart's individual RICO claims, stating that his alleged injuries were not separate from those of other shareholders. The court noted, “Stewart alleges several cognizable injuries in his complaint, but they all are derived from a diminution in imINDY’s value—necessarily a loss incurred by all shareholders.” This ruling clarified that shareholders cannot sue individually for losses that affect the corporation as a whole.

Impact

This ruling has significant implications for business owners and shareholders. It reinforces the principle that shareholders must demonstrate a unique injury to pursue individual claims related to corporate mismanagement. The court's decision may deter similar lawsuits where shareholders seek to recover losses that are fundamentally tied to the corporation's overall performance.

Moreover, the ruling emphasizes the importance of maintaining accurate corporate records and adhering to established agreements. Business partners must be cautious about verbal agreements and ensure that all financial decisions are documented and transparent to avoid disputes in the future.

What's Next

Stewart's options for appeal are limited. While he can seek further legal recourse, the court's ruling effectively closes the door on his RICO claims. There are no indications of related cases pending that could affect this ruling. Stewart's counsel has indicated that he may consider pursuing claims in state court, but no formal steps have been announced.