United States of America v. Lawrence Jeffrey Brooks
April 28, 2026·25-6920·Per Curiam·By James Taylor
The Fourth Circuit dismissed an appeal filed by a federal prisoner seeking relief under Section 2255 of Title 28. The court concluded the appellant failed to make a substantial showing of the denial of a constitutional right required to obtain a certificate of appealability.
Background
Lawrence Jeffrey Brooks filed a motion under Section 2255 of Title 28 seeking relief from his federal conviction. The district court denied relief on his constitutional claims. Brooks then sought to appeal that denial.
The court’s reasoning
The court explained that an order denying relief on a Section 2255 motion is not appealable unless a circuit justice or judge issues a certificate of appealability. To obtain such a certificate, a prisoner must make a substantial showing of the denial of a constitutional right. The court reviewed the record and concluded that Brooks had not made the requisite showing that reasonable jurists could find the district court’s assessment debatable or wrong.
What it means going forward
The dismissal prevents the prisoner from pursuing further appellate review of the district court’s denial of his Section 2255 motion.
