# Ronald Emrit v. Board of Immigration Appeals (BIA)

> Court of Appeals for the Fourth Circuit · July 25, 2022

URL: https://www.frixlaw.com/law-library/cases/7374967

## Case

- **Court:** Court of Appeals for the Fourth Circuit
- **Decided:** July 25, 2022
- **Precedential status:** Unpublished
- **Opinion:** Opinion
- **Cited by:** 0 later opinions in the Frix Law Library

## Citator (automated)

- No negative treatment found by the automated citator. That is not the same as a confirmation that the case is good law; read the citing cases.
- Full citator and citing cases: https://www.frixlaw.com/law-library/cases/7374967

## How later opinions describe it (automated extraction)

- explaining that “a dismissal for lack of standing—or any other defect in subject matter jurisdiction—must be one without prejudice” (cleaned up)

## Opinion text

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UNPUBLISHED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Affirmed as modified by unpublished per curiam opinion.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Unpublished opinions are not binding precedent in this circuit.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

2

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Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/7374967. Public record. Not legal advice.