Faline Arnold, proceeding pro se, appealed a district court order in the Eastern District of Virginia that granted summary judgment in favor of her employer, Huntington Ingalls Incorporated. Arnold had brought claims under Title VII of the Civil Rights Act of 1964 and the Family and Medical Leave Act. The district court had adopted a magistrate judge's recommendation to dismiss the case on summary judgment and had also denied Arnold's motion to vacate the judgment under Federal Rule of Civil Procedure 60(b). Arnold appealed these orders, arguing that the lower court erred in its application of the law and facts.
The panel of three circuit judges reviewed the case de novo, applying the standard of review required for summary judgment. The court emphasized that its review was limited to the specific issues Arnold preserved in her informal brief, citing Fourth Circuit Rule 34(b) and the precedent set in Jackson v. Lightsey. The court noted that under Fourth Circuit rules, the informal brief serves as the primary vehicle for preserving issues for appeal. After examining the record and the arguments raised in that brief, the court found no reversible error in the district court's decision. The opinion did not address the merits of the discrimination or leave claims in detail, instead concluding that the lower court's adoption of the magistrate's recommendation was correct based on the limited scope of the appeal.
The judgment in favor of Huntington Ingalls Incorporated stands, leaving Arnold without relief on her employment discrimination and leave violation allegations. The decision reinforces the procedural requirement that appellants must clearly preserve their arguments in their briefs, as the appellate court will not consider issues outside the scope of the informal brief filed by a pro se litigant. No remand instructions were issued as the case was affirmed.