Presidential Candidate Number P60005535 v. Cherniavska
June 24, 2026·26-1200·Per Curiam·By Aisha Johnson
The United States Court of Appeals for the Fourth Circuit dismissed an appeal filed by a self-represented litigant before the district court entered a final order. The court held that it lacked jurisdiction because the appeal was premature and did not meet statutory requirements for interlocutory review.
Ronald Satish Emrit, proceeding pro se, filed a civil complaint and subsequently filed a notice of appeal one month later. At the time of the appeal, the district court had not entered any orders. The appeal was from the United States District Court for the Western District of Virginia.
The court’s reasoning
The court explained that it may exercise jurisdiction only over final orders under Section twelve hundred and ninety-one of Title twenty-eight, or certain interlocutory and collateral orders under Section twelve hundred and ninety-two of Title twenty-eight and Federal Rule of Civil Procedure fifty-four. The court found that Emrit did not seek to appeal a final order or an appealable interlocutory or collateral order. Consequently, the court dismissed the appeal for lack of jurisdiction.
What it means going forward
The dismissal prevents the appellate court from reviewing the merits of the underlying case at this time. The litigant must file a new notice of appeal if they wish to challenge a dismissal order entered after the initial notice of appeal.
