In June 2022 in Glow in One Mini Golf v. Walz, the U.S. Court of Appeals for the Eighth Circuit joined at least three other circuits in concluding that expired state laws imposed in 2020 to stop or slow the spread of COVID-19 are not "capable of repetition but evading review," thereby 8th Circuit Spotlightending appeals challenging their constitutionality. But the most significant part of the decision may be a paragraph of dicta that could have dire consequences for plaintiffs hoping to seek just compensation in federal courts for alleged takings by states.