4th Cir.

TAUREAN SMALL v. FEDERAL TRADE COMMISSION; NATIONAL TELECOMMUNICATIONS AND INFORMATION ADMINISTRATION

April 30, 2026 ·25-2256 ·Per Curiam · By Maria Santos

The United States Court of Appeals for the Fourth Circuit affirmed a district court order dismissing a civil action for lack of subject matter jurisdiction. The court found no reversible error in the lower court's adoption of a magistrate judge's recommendation.

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Background

Taurean Small filed a civil action in the United States District Court for the Eastern District of North Carolina against the Federal Trade Commission and the National Telecommunications and Information Administration. The district court adopted a recommendation from a magistrate judge and dismissed the case for lack of subject matter jurisdiction.

The court’s reasoning

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

What it means going forward

The dismissal for lack of subject matter jurisdiction stands, ending the plaintiff’s ability to pursue the claims in federal court on the current record.

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