April 30, 2026·25-6568·Per Curiam·By Aisha Johnson
The United States Court of Appeals for the Fourth Circuit affirmed the district court's dismissal of a civil rights action. The court held that the appellant forfeited appellate review by failing to challenge the basis for the dismissal in his informal brief.
Rodney E. Cobbs filed a pro se action under 42 U.S.C. Section 1983 in the United States District Court for the Eastern District of North Carolina. The district court dismissed the action without prejudice. Cobbs appealed the dismissal.
The court’s reasoning
The court confined its review to the issues raised in the appellant’s informal brief. Because Cobbs did not challenge the basis for the district court’s disposition in that brief, he forfeited appellate review of the order. The court cited Jackson v. Lightsey to establish that the informal brief limits the scope of review in the Fourth Circuit.
What it means going forward
The decision reinforces that pro se litigants must explicitly raise all challenges to a dismissal in their informal briefs to preserve those issues for appeal in the Fourth Circuit.
