Tremel Marquis Rosser, proceeding pro se, filed multiple civil actions in the United States District Court for the Eastern District of Virginia against a wide array of defendants, including federal officials like Marco Rubio, President Donald Trump, and various law enforcement personnel. The district court dismissed these actions, and Rosser appealed the various dismissal orders to the Fourth Circuit. The appeals were consolidated under a single docket number, 25-2284, and submitted for review without oral argument. The core dispute on appeal was not the merits of the underlying claims, but whether the appellate court could review the district court's decisions given the format and content of Rosser's filing.
The Fourth Circuit issued an unpublished per curiam opinion focusing entirely on procedural forfeiture. The court explained that under Fourth Circuit Rule 34(b), when a pro se litigant files an informal brief, the scope of appellate review is strictly confined to the issues raised in that brief. The court noted that Rosser's informal briefs failed to challenge the specific legal basis for the district court's dispositions. Citing Jackson v. Lightsey, 775 F.3d 170, 177 (4th Cir. 2014), the court emphasized that the informal brief is a critical document that dictates the boundaries of the appeal. Because Rosser did not preserve any specific arguments regarding the legal grounds for dismissal in his informal brief, the court determined he had forfeited the right to appellate review of those orders. Consequently, the court affirmed the lower court's orders without addressing the substantive merits of the underlying civil actions.
The district court's orders dismissing Rosser's civil actions against the named federal officials remain in effect. The decision reinforces the strict procedural requirements for pro se litigants in the Fourth Circuit, specifically the necessity of clearly identifying legal arguments in informal briefs to avoid forfeiture. No remand instructions were issued, and the case is closed at the appellate level.
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