The opinion
USCA4 Appeal: 23-7152 Doc: 10 Filed: 04/23/2024 Pg: 1 of 3
UNPUBLISHED
UNITED STATES COURT OF APPEALS
FOR THE FOURTH CIRCUIT
No. 23-7152
MICHAEL ISAIAH ANDERSON, JR.,
Plaintiff - Appellant,
v.
MAJOR BROWN, Florence County Detention Center; CAPTAIN PATTON,
Florence County Detention Center; C. NEAL, Sergeant Florence County Detention
Center,
Defendants - Appellees.
Appeal from the United States District Court for the District of South Carolina, at
Greenville. Henry M. Herlong, Jr., Senior District Judge. (6:23-cv-03018-HMH)
Submitted: March 19, 2024 Decided: April 23, 2024
Before WILKINSON, WYNN, and HARRIS, Circuit Judges.
Vacated and remanded by unpublished per curiam opinion.
Michael Isaiah Anderson, Jr., Appellant Pro Se.
Unpublished opinions are not binding precedent in this circuit.
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PER CURIAM:
Michael Isaiah Anderson, Jr., appeals the district court’s order denying relief on his
42 U.S.C. § 1983 complaint. The district court referred this case to a magistrate judge
pursuant to 28 U.S.C. § 636(b)(1)(B). The magistrate judge recommended that relief be
denied because Anderson did not allege that any individual defendant acted with a
sufficiently culpable state of mind and because some of the relief he sought—replacement
of the facility’s plumbing and water testing—was not relief that the district court could
award. Anderson timely filed objections, but the district court determined such objections
merely restated his claims and were therefore insufficiently specific to warrant de novo
review. Thus, after reviewing the magistrate judge’s recommendation for only clear error,
the district court adopted the magistrate judge’s recommendation and dismissed
Anderson’s claims. Anderson timely appealed.
We review the sufficiency of objections to a magistrate judge’s recommendations
de novo. Elijah v. Dunbar, 66 F.4th 454, 461 (4th Cir. 2023). “To trigger de novo review,
an objecting party ‘must object to the finding or recommendation on that issue with
sufficient specificity so as reasonably to alert the district court of the true ground for the
objection.’” Id. at 460 (quoting United States v. Midgette, 478 F.3d 616, 622 (4th Cir.
2007)).
Here, although the district court was correct in observing that Anderson’s objections
largely restated his claims, we made clear in Elijah that, especially given our obligation to
construe pro se filings liberally, objections which merely restate claims are “sufficiently
specific because [they] ‘alert[] the district court that [the litigant] believed the magistrate
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judge erred in recommending dismissal of those claims.’” Id. (quoting Martin v. Duffy, 858
F.3d 239, 246 (4th Cir. 2017)). Moreover, Anderson stated in his objections that “[t]he
Administration have to be aware of what going on so that deliberating depriving me of
life.” E.R. 103 (errors uncorrected). Construed liberally, this statement was Anderson’s
attempt to alert the district court to his belief that the defendants acted with a sufficiently
culpable state of mind. Thus, Anderson sufficiently alerted the district court that he
disagreed generally with the magistrate judge’s recommendation to dismiss his complaint
and specifically with the magistrate judge’s conclusions regarding the sufficiency of his
mental state allegations.
Accordingly, Anderson’s objections were sufficiently sufficient to warrant de novo
review of the portions of the magistrate judge’s order to which he objected. We therefore
vacate the district court’s order and remand for de novo review.
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.
VACATED AND REMANDED
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