Quentin W. Blanchard v. General Services Administration
June 3, 2026·26-1010·Per Curiam·By Maria Santos
The United States Court of Appeals for the Fourth Circuit affirmed a district court dismissal for lack of subject matter jurisdiction. The appellate court held that the appellant forfeited the right to challenge the jurisdictional ruling by failing to address it in his informal brief.
Background
Quentin W. Blanchard, proceeding pro se, appealed a district court order dismissing his civil action against the General Services Administration for lack of subject matter jurisdiction. Blanchard sought over sixty-nine million dollars in contract payments and damages, alleging the agency failed to perform under various contracts. The district court ruled that under the Big Tucker Act, claims exceeding ten thousand dollars must be brought in the United States Court of Federal Claims.
The court’s reasoning
The court confined its review to the issues raised in the appellant’s informal brief. Because Blanchard’s brief did not challenge the district court’s ruling on subject matter jurisdiction, the court held that he forfeited appellate review of that dismissal order.
What it means going forward
This decision reinforces that pro se litigants must explicitly raise jurisdictional challenges in their informal briefs to preserve them for appeal in the Fourth Circuit.
