La Belle Dairy
ST. LOUIS — A federal judge has denied a motion by Sharpe Holdings to disqualify opposing counsel in an ongoing property dispute with La Belle Dairy, ruling that the request was filed too late and therefore waived.
In an opinion, memorandum and order dated April 23, U.S. District Judge Henry Edward Autrey found that Sharpe Holdings waited nearly a year after the lawsuit was filed to seek the disqualification of attorneys Jeffrey L. Schultz, Angela Kennedy and the law firm Armstrong Teasdale.
The court concluded that this delay was unjustified and that Sharpe Holdings had forfeited its right to raise the issue.
The underlying case stems from a dispute over approximately 6,100 acres of farmland adjacent to a dairy operation in La Belle, Mo.
La Belle Dairy purchased the dairy from Sharpe Holdings in 2017 and later entered into a lease agreement for the surrounding farmland that included provisions governing a future sale of the leased property.
The dispute arose after La Belle alleged that Sharpe Holdings refused to sell the land as required under the lease agreement.
Shortly after filing suit, La Belle sought and obtained a temporary restraining order preventing Sharpe Holdings from evicting it or interfering with its use of the leased land.
Sharpe Holdings argued that Armstrong should be disqualified due to a conflict of interest, asserting that the firm had previously represented the company in matters involving the Occupational Safety and Health Administration between 2015 and 2018.
According to Sharpe Holdings, the prior representation either continued through the time the lawsuit was filed or was substantially related to the current dispute, thereby creating an impermissible conflict under professional conduct rules.
La Belle opposed the motion, contending that Sharpe Holdings was no longer a client when the lawsuit was filed and that the prior OSHA-related work was unrelated to the present property dispute.
La Belle also argued that Sharpe Holdings waited too long to raise the issue.
The court focused its analysis on the timing of the motion and determined that Sharpe Holdings either knew or should have known about Armstrong’s involvement in the case from the outset.
Autrey noted that Armstrong's attorneys signed and filed numerous key documents, including the complaint, motions, discovery requests, and other filings and actively participated in hearings and mediation.
The court rejected Sharpe Holdings’ claim that it did not realize Armstrong was representing La Belle until September 2025, calling that position “untenable.”
Autrey also highlighted the substantial work already completed by Armstrong in the case, including obtaining the temporary restraining order, participating in discovery and engaging in mediation.
Disqualifying counsel at that stage, the court said, would unfairly prejudice La Belle by depriving it of its chosen attorneys after significant preparation had already occurred.
Because the motion was deemed untimely, the court did not address whether an actual conflict of interest existed.
U.S. District Court for the Eastern District of Missouri case number: 2:25-cv-00014
