4th Cir.

Leonard W. Houston v. United States of America

May 22, 2026 ·26-1311 ·Per Curiam · By James Taylor

The United States Court of Appeals for the Fourth Circuit dismissed an appeal filed by Leonard W. Houston regarding a district court order denying his motion to amend a complaint. The court held that the order in question was neither a final order nor an appealable interlocutory or collateral order.

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Background

Leonard W. Houston filed a pending action under the Camp Lejeune Justice Act of two thousand and twenty-two in the United States District Court for the Eastern District of North Carolina. The district court issued a text order on February twenty-seventh, two thousand and twenty-six, denying his motion for leave to amend and supplement his short-form complaint. Houston sought to appeal this order.

The court’s reasoning

The court explained that it may exercise jurisdiction only over final orders and certain interlocutory and collateral orders under Section twelve ninety-one of Title twenty-eight of the United States Code and Section twelve ninety-two of Title twenty-eight of the United States Code. The order Houston seeks to appeal is neither a final order nor an appealable interlocutory or collateral order. Accordingly, the court dismissed the appeal for lack of jurisdiction.

What it means going forward

The dismissal prevents appellate review of the district court’s procedural ruling on the amendment motion until a final judgment is entered in the underlying case.

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