4th Cir.

United States Court of Appeals for the Fourth Circuit

Every decision we've summarized from United States Court of Appeals for the Fourth Circuit.

Apr 28 2026
25-7060 Per Curiam

LAWRENCE L. INGRAM v. DOYET A. EARLY, III; J. CHRISTOPHER WILSON; WARDEN WILLIE DAVIS; COURTNEY BENNETT; OFFICER ADKINSON; DEPARTMENT OF PROBATION; UNITED STATES OF AMERICA

The Fourth Circuit affirmed the dismissal of Lawrence Ingram's civil action because his objections to the magistrate judge's recommendation were untimely and lacked specific factual or legal grounds. This procedural failure waived his right to appellate review of the district court's underlying order.

Civil Civil Rights - PLRA / Prisoner
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Apr 28 2026
24-4604 Panel Decision

UNITED STATES OF AMERICA v. MILTON CHRISTOPHER ALLEN

The Fourth Circuit reversed a district court's suppression order, ruling that evidence seized from an arrestee's bags would have been inevitably discovered through lawful inventory searches. The court held that established departmental policies mandated searching all personal property of arrestees, rendering the warrantless search incident to arrest unnecessary to justify admission.

Criminal Firearms Fourth Amendment - Search & Seizure
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Apr 28 2026
24-2073 2-1

RICHARD P. HARROLD Plaintiff – v. LEWIS J. HAGEN

The Fourth Circuit vacated the district court's grant of qualified immunity, holding that a non-threatening, unarmed, and passively resisting suspect possesses a clearly established Fourth Amendment right to be free from unnecessary K-9 deployment. The court concluded that Officer Hagen's use of force was disproportionate under existing precedent, requiring the case to proceed to trial rather than being dismissed at this procedural stage.

Civil Civil Rights - Section 1983 Qualified Immunity
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Apr 28 2026
25-7000 Per Curiam

Weldon Eugene Holtzclaw, Jr. v. Judge Stokes; Judge Stone; Wendy Moses; Marjorie Morgan; Jerri

The Fourth Circuit affirmed the dismissal of a pro se civil rights complaint because the appellant failed to challenge the specific legal basis for the lower court's order in his informal brief. Under Fourth Circuit Rule 34(b), this omission forfeited appellate review, leaving the district court's dismissal and denial of postjudgment motions intact.

Civil Civil Rights - Section 1983 Forfeiture / Penalty
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