Background
Karen Williams, proceeding pro se, appealed orders from the United States District Court for the Eastern District of North Carolina granting the defendants’ motions under Federal Rule of Civil Procedure twelve comma b comma four and five. The district court had dismissed her consolidated civil actions for failure to effect proper service of process.
The court’s reasoning
The court confined its review to the issues raised in the appellant’s informal brief. Because Williams’ informal briefs did not challenge the basis for the district court’s disposition, she forfeited appellate review of the court’s orders. The court cited Jackson v. Lightsey to note that under Fourth Circuit rules, review is limited to issues preserved in the informal brief.
What it means going forward
The judgment of the district court dismissing the housing authority case for improper service remains in effect, and the appellant’s claims were not addressed on the merits.