Background
Ronald Satish Emrit, proceeding pro se, appealed a district court order that dismissed his civil complaint as frivolous pursuant to Section nineteen hundred fifteen, subsection (e)(two) of Title twenty-eight of the United States Code. The district court also imposed a prefiling review requirement on any future filings by Emrit.
The court’s reasoning
The court reviewed the record and found no reversible error in the district court’s determination that the complaint failed to present a coherent claim for relief. Regarding the prefiling review limitation, the court noted that Emrit’s informal brief did not challenge the district court’s imposition of that requirement. Citing Jackson v. Lightsey, the court held that under Fourth Circuit rules, review is limited to issues preserved in the informal brief, meaning Emrit forfeited appellate review of that specific ruling.
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
The appellant’s complaint remains dismissed, and any future filings by the appellant must undergo prefiling review before being accepted by the court.
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