“The informal brief is an important document; under Fourth Circuit rules, our review is limited to issues preserved in that brief.”
How later courts described this case
- “The informal brief is an important document; under Fourth Circuit rules, our review is limited to issues preserved in that brief.”
- explaining that “a dismissal for lack of standing—or any other defect in subject matter jurisdiction—must be one without prejudice” (cleaned up)
Written by the judges who cited it.
The opinion
USCA4 Appeal: 22-1338 Doc: 8 Filed: 07/25/2022 Pg: 1 of 2
UNPUBLISHED
UNITED STATES COURT OF APPEALS
FOR THE FOURTH CIRCUIT
No. 22-1338
RONALD SATISH EMRIT,
Plaintiff - Appellant,
v.
BOARD OF IMMIGRATION APPEALS (BIA); CITIZENSHIP &
IMMIGRATION SERVICES (CIS); CUSTOMS AND BORDER PATROL (CBP);
STATE DEPARTMENT; DEPARTMENT OF HOMELAND SECURITY (DHS),
Defendants - Appellees.
Appeal from the United States District Court for the District of Maryland, at Greenbelt.
George Jarrod Hazel, District Judge. (8:22-cv-00623-GJH)
Submitted: July 21, 2022 Decided: July 25, 2022
Before MOTZ, HARRIS, and RUSHING, Circuit Judges.
Affirmed as modified by unpublished per curiam opinion.
Ronald Satish Emrit, Appellant Pro Se.
Unpublished opinions are not binding precedent in this circuit.
USCA4 Appeal: 22-1338 Doc: 8 Filed: 07/25/2022 Pg: 2 of 2
PER CURIAM:
Ronald Satish Emrit appeals the district court’s order dismissing his complaint for
lack of jurisdiction. On appeal, we confine our review to the issues raised in the informal
brief. See 4th Cir. R. 34(b). Because Emrit’s informal brief does not challenge the basis
for the district court’s disposition, he has forfeited appellate review of the court’s order.
See Jackson v. Lightsey, 775 F.3d 170, 177 (4th Cir. 2014) (“The informal brief is an
important document; under Fourth Circuit rules, our review is limited to issues preserved
in that brief.”). Accordingly, we affirm the district court’s judgment but modify the
dismissal to be without prejudice. See Ali v. Hogan, 26 F.4th 587, 600 (4th Cir. 2022)
(explaining that “a dismissal for lack of standing—or any other defect in subject matter
jurisdiction—must be one without prejudice” (cleaned up)). We dispense with oral
argument because the facts and legal contentions are adequately presented in the materials
before this court and argument would not aid the decisional process.
AFFIRMED AS MODIFIED
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