4th Cir.

Robert Lee Strother v. Captain R. Russell

March 26, 2026 ·25-6981 ·Per Curiam · By Raj Patel

The United States Court of Appeals for the Fourth Circuit dismissed an appeal filed by a pro se plaintiff challenging a district court's dismissal of his complaint. The appellate court held that the order being appealed was neither final nor an appealable interlocutory order under federal law.

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Background

Robert Lee Strother filed a complaint against several law enforcement officials and a county EMS provider. The district court granted motions to dismiss the complaint against certain defendants, ruling that the claims were barred by the three-year statute of limitations. Strother sought to appeal this order immediately.

The court’s reasoning

The court explained that it may exercise jurisdiction only over final orders under Section twelve hundred and ninety-one of Title twenty-eight of the United States Code, or certain interlocutory and collateral orders under Section twelve hundred and ninety-two and Federal Rule of Civil Procedure fifty-four. The order Strother sought to appeal was neither a final order nor an appealable interlocutory or collateral order. Consequently, the court lacked jurisdiction to hear the appeal.

The order Strother seeks to appeal is neither a final order nor an appealable interlocutory or collateral order.

Per Curiam Opinion

What it means going forward

The dismissal prevents the plaintiff from challenging the statute of limitations ruling until a final judgment is entered in the district court, unless a specific exception for interlocutory orders applies.