4th Cir.

Presidential Candidate Number P60005535 v. Quantico, Virginia

June 24, 2026 ·26-1201 ·Per Curiam · By James Taylor

The United States Court of Appeals for the Fourth Circuit dismissed an appeal filed by a self-styled presidential candidate before the district court issued a final order. The court held that it lacked jurisdiction because the appeal was premature and did not meet statutory requirements for reviewing non-final decisions.

Listen to this decision 0:00 / 0:55

Background

Ronald Satish Emrit, identifying himself as Presidential Candidate Number P60005535, filed a civil complaint in the United States District Court for the Western District of Virginia. Approximately two months after filing the complaint, he filed a notice of appeal before the district court had entered any orders.

The court’s reasoning

The court explained that it may exercise jurisdiction only over final orders under Section twelve ninety-one of Title twenty-eight of the United States Code, or certain interlocutory and collateral orders under Section twelve ninety-two and Federal Rule of Civil Procedure fifty-four. Emrit did not appeal a final order or an appealable interlocutory or collateral order. The court noted that a notice of appeal cannot supply jurisdiction to review a dismissal order entered after the notice was filed.

What it means going forward

The appeal is dismissed without prejudice to filing a new notice of appeal once a final order or appealable interlocutory order is entered by the district court.