4th Cir.

Okechukwu Desmond Amadi v. Warden Katina Heckard

July 20, 2026 ·25-6514 ·Per Curiam ·Per Curiam · By James Taylor

The Fourth Circuit affirmed the dismissal of a habeas corpus petition where the petitioner failed to challenge the district court's order in his informal brief.

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Background

Okechukwu Desmond Amadi filed a petition under Section twenty-eight United States Code Section two thousand two hundred forty-one in the Eastern District of North Carolina. The district court ordered him to show cause why his petition should not be dismissed as moot. He failed to comply, and the court dismissed the petition without prejudice.

The court’s reasoning

The appellate court confined its review to issues raised in the informal brief. Because the appellant did not challenge the basis for the district court’s disposition in that brief, he forfeited appellate review of the order.

The informal brief is an important document; under Fourth Circuit rules, our review is limited to issues preserved in that brief.

Jackson v. Lightsey, 775 F.3d 170, 177 (4th Cir. 2014)

What it means going forward

Establishes forfeiture of appellate review if informal brief does not challenge district court disposition.