Latoshia L. Reeves, proceeding pro se, filed a lawsuit in the United States District Court for the District of Maryland against Guidehouse, LLP and its CEO, Scott McIntyre. During the proceedings, Reeves filed several motions: a motion to shield her case from public records, motions for default judgment against the defendants, and a motion to expedite a decision on the default judgment motions. The district court denied all of these requests. Reeves then attempted to appeal these denials to the Fourth Circuit, arguing that the lower court's actions warranted immediate review.
The Fourth Circuit, in an unpublished per curiam opinion, focused strictly on the statutory limits of its appellate jurisdiction. Under 28 U.S.C. § 1291, this court may exercise jurisdiction only over final orders, and under 28 U.S.C. § 1292 and Fed. R. Civ. P. 54(b), only over certain interlocutory and collateral orders. The court applied the standard set forth in Cohen v. Beneficial Indus. Loan Corp. to determine if the order qualified for the collateral order doctrine. The court concluded that the order denying Reeves' motions to shield records, enter default judgment, or expedite those motions was neither a final order nor an appealable interlocutory or collateral order. Because the order did not fit within the narrow exceptions allowing for immediate appeal, the court held that it had no authority to hear the case on the merits.
The appeal is dismissed, meaning the district court's orders denying Reeves' motions remain in effect. Reeves cannot challenge these specific procedural rulings in the Fourth Circuit at this time. She must wait until a final judgment is entered in the district court to appeal, unless she can secure a certification from the district court under Rule 54(b) or find another statutory basis for interlocutory review. The underlying claims against Guidehouse and McIntyre continue in the district court.