4th Cir.

Lorenzo Dominic Richardson v. Gerald Baker; Jet Insurance Company; On Point Risk Solutions; Adam B. Midgette; Thomas L. Teal; Tim C. Jarvis; J.R. Moore; David S. Brannon; Wake C...

Lorenzo Dominic Richardson v. Gerald Baker; Jet Insurance Company; On Point Risk Solutions; Adam B. Midgette; Thomas L. Teal; Tim C. Jarvis; J.R. Moore; David S. Brannon; Wake C…

March 30, 2026 ·25-2068 ·Per Curiam · By Aisha Johnson

The Fourth Circuit dismissed the appeal regarding the underlying dismissal and denial of post-judgment motions because the notice of appeal was filed after the mandatory thirty-day deadline. The court affirmed the separate order enjoining further filings, finding no reversible error in the district court's decision.

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Lorenzo Dominic Richardson, proceeding pro se, sought to appeal three orders from the United States District Court for the Eastern District of North Carolina. The district court had previously dismissed his civil action against various defendants, including insurance companies and law enforcement officials. Richardson also filed a fourth post-judgment motion, which the district court denied. Additionally, the district court entered an order enjoining Richardson from making further filings in that case. Richardson attempted to appeal all three orders, but the timing of his filings varied across the different judgments.

The court addressed two distinct issues based on the timing of the filings. First, regarding the dismissal of the civil action and the denial of the post-judgment motion, the court applied Federal Rule of Appellate Procedure 4(a)(1)(A), which mandates that parties have thirty days after the entry of a final judgment or order to file a notice of appeal. The court noted that the judgment of dismissal was entered on November 7, 2024, making the appeal period expire on December 9, 2024. The order denying the post-judgment motion was entered on July 23, 2025, with the appeal period expiring on August 22, 2025. Richardson filed his notice of appeal on September 5, 2025, which was late for both orders. The court emphasized that the timely filing of a notice of appeal is a jurisdictional requirement, citing Bowles v. Russell, 551 U.S. 205, 214 (2007). Because Richardson failed to file a timely notice or obtain an extension, the court dismissed the appeal as to those orders. Second, regarding the order enjoining further filings entered on August 18, 2025, the court found that Richardson had filed a timely notice of appeal for this specific order. The court reviewed the record and determined there was no reversible error in the district court's decision to enjoin further filings, leading to an affirmation of that specific order.

The lower court judgments dismissing the civil action and denying the post-judgment motions remain final and binding on the appellant. The order enjoining Richardson from further filings in the case is also affirmed. The appellant has no further right to appeal the dismissal or the denial of the post-judgment motion due to the missed deadline, and the injunction against future filings stands.

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