Background
Phillip Charles Reeves, proceeding pro se, sought to appeal a magistrate judge’s order in the District Court for the District of South Carolina. The order directed Reeves to file a second amended complaint containing all claims he intended to pursue. Reeves filed this appeal immediately following that directive.
The court’s reasoning
The court explained that its jurisdiction is limited to final orders under Section twelve hundred and ninety-one of Title twenty-eight of the United States Code, as well as certain interlocutory and collateral orders under Section twelve hundred and ninety-two and Federal Rule of Civil Procedure fifty-four. The court found that the order Reeves sought to appeal was neither a final order nor an appealable interlocutory or collateral order. Consequently, the court lacked the authority to hear the appeal.
The order Reeves seeks to appeal is neither a final order nor an appealable interlocutory or collateral order.
USCA4 Appeal: 25-6496 Doc: 15 Filed: 03/17/2026 Pg: 2 of 2
What it means going forward
This decision reinforces the final judgment rule, preventing piecemeal appeals in civil rights cases until a district court issues a final ruling or a specific statutory exception applies.
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