4th Cir.

UNITED STATES OF AMERICA v. RONALD SHAW

March 10, 2026 ·25-6313 ·Per Curiam · By James Taylor

The Fourth Circuit Court of Appeals dismissed Ronald Shaw's appeal because he failed to obtain a required certificate of appealability. The court found that Shaw did not make a substantial showing that the district court's denial of his habeas motion was debatable or wrong.

Ronald Shaw, proceeding pro se, sought to appeal a district court order that denied relief on his motion under 28 U.S.C. § 2255. This motion challenged the validity of his conviction or sentence. The district court had adopted a magistrate judge's recommendation and denied Shaw's request for relief. Before an appellate court can review such a denial, the prisoner must first obtain a certificate of appealability from a circuit judge or justice. Without this certificate, the appeal cannot proceed, regardless of the merits of the underlying claims.

The court applied the standard set forth in 28 U.S.C. § 2253(c)(2), which requires a prisoner to make a 'substantial showing of the denial of a constitutional right' to obtain a certificate of appealability. The court noted that when a district court denies relief on the merits, a prisoner satisfies this standard by demonstrating that reasonable jurists could find the district court's assessment of the constitutional claims debatable or wrong. Citing Buck v. Davis, the court emphasized that this is a threshold requirement designed to filter out frivolous appeals. After independently reviewing the record, the Fourth Circuit concluded that Shaw had not met this burden. The court determined that reasonable jurists could not find the district court's assessment debatable or wrong, and therefore, no certificate of appealability should issue.

The dismissal of the appeals means that the district court's order denying Shaw's § 2255 motion stands final. Shaw cannot pursue further appellate review of the constitutional claims in the Fourth Circuit unless he can secure a certificate of appealability, which the court has effectively precluded by finding no substantial showing was made. The case is closed at the appellate level.