4th Cir.

TAUREAN SMALL v. OPEN AI LP; MICROSOFT CORPORATION; GOOGLE LLC; META PLATFORMS, INC.; AMAZON.COM, INC.; ADOBE, INC

June 11, 2026 ·25-2255 ·Per Curiam · By Aisha Johnson

The United States Court of Appeals for the Fourth Circuit affirmed a district court order dismissing a pro se civil action. The appellate court found no reversible error in the lower court's decision to dismiss the amended complaint under federal statute.

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Background

Taurean Small, proceeding pro se, filed an amended civil action in the United States District Court for the Eastern District of North Carolina against Open AI LP, Microsoft Corporation, Google LLC, Meta Platforms, Inc., Amazon.com, Inc., and Adobe, Inc. The district court adopted a magistrate judge’s recommendation and dismissed the case under Section nineteen hundred fifteen of Title twenty-eight of the United States Code.

The court’s reasoning

The court reviewed the record and found no reversible error in the district court’s order. The appellate court determined that the facts and legal contentions were adequately presented in the materials before the court, making oral argument unnecessary for the decisional process.

What it means going forward

The dismissal of the pro se civil action stands, and the plaintiff’s claims against the technology defendants are not proceeding in the Fourth Circuit.