4th Cir.

Charles Claude Ramsey v. Unknown

March 26, 2026 ·26-6122 ·Per Curiam · By Aisha Johnson

The United States Court of Appeals for the Fourth Circuit affirmed a district court order dismissing a pro se civil action without prejudice. The appellate court found no reversible error in the lower court's determination that the plaintiff's letter did not constitute a formal complaint.

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Background

The appellant, Charles Claude Ramsey, filed a one-page letter with the district court clerk requesting a complaint form under Section nineteen eighty-three of Title forty-two of the United States Code. The district court determined the letter did not intend to initiate a civil action and dismissed the case without providing leave to amend.

The court’s reasoning

The court reviewed the record and discerned no reversible error. The district court’s dismissal was affirmed because the appellant did not contest the characterization of his letter as not intending to initiate a civil action.

We have reviewed the record and discern no reversible error.

Ramsey v. Unknown, No. 2:25-cv-00740-JKW-LRL (E.D. Va. Jan. 5, 2026)

What it means going forward

The decision reinforces that a mere request for a complaint form does not constitute the filing of a civil action under Section nineteen eighty-three.