--- title: "United States v. Houck" citation: "2 F.4th 1082 (8th Cir. 2021)" authority_id: "AUTH-CA8-HOUCK-2-F4TH-1082" authority_type: "case" jurisdiction: "federal_eighth_circuit" precedential_status: "binding_in_ca8" official_url: "https://ecf.ca8.uscourts.gov/opndir/21/06/202216P.pdf" url: "https://jason93.com/legal/federal-process/authorities/AUTH-CA8-HOUCK-2-F4TH-1082/" legal_review: "2026-08-25" links_checked: "2026-10-15" links_available: 1 links_checked_count: 1 license: "CC BY 4.0" --- # United States v. Houck ## Holdings used - The filing prerequisite is mandatory when raised; an unexhausted motion is dismissed without prejudice, and the asserted home-confinement-memorandum futility theory did not excuse compliance. ## Material limitation Binding only in the Eighth Circuit and only for the bounded procedural postures in the linked claims. Official published opinion reviewed. The futility holding is limited to the theory presented; compassionate release and BOP home-confinement placement are kept distinct. A comprehensive commercial citator was not run. ## Official source and pinpoints 2 F.4th 1082 (8th Cir. 2021), 2 F.4th 1084–85: ## Linked claims - `CLM-CIR8-004` ## Used in - [Eighth Circuit Overlay](https://jason93.com/legal/federal-process/modules/95-circuit-overlays/eighth-circuit.md)