Beckie Boddie Appeal - Affirmed in Part, Dismissed in Part
Summary
The Fourth Circuit affirmed the District of Maryland's order striking Beckie Boddie's Fed. R. Civ. P. 60(b)(4) motion for lack of standing, finding she was not a party to the underlying fraud redress proceedings and did not qualify for nonparty appellate standing. The court dismissed her appeal challenging the district court's fraud victim redress plan.
What changed
Beckie Boddie, proceeding pro se, attempted to challenge district court orders establishing a fraud victim redress plan by filing a Rule 60(b)(4) motion in an action to which she was not a party. The district court struck her motion, and the Fourth Circuit affirmed, construing her appeal as a request to intervene and finding no abuse of discretion in its refusal to allow intervention under Gould v. Alleco. The court further dismissed her challenge to the redress plan for lack of nonparty appellate standing, since she did not actively participate in the underlying district court proceedings.
Affected parties—particularly nonparties seeking to challenge court-ordered redress or restitution plans—should note that appellate standing requires both an interest in the litigation and active participation in the proceedings below. This ruling reinforces that courts will not entertain appeals from parties who were strangers to the original action, absent exceptional circumstances not present here.
What to do next
- Monitor for related proceedings in the underlying fraud redress case
Archived snapshot
Apr 10, 2026GovPing captured this document from the original source. If the source has since changed or been removed, this is the text as it existed at that time.
UNPUBLISHED
UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT
No. 26-1130
In Re: BECKIE BODDIE, Movant - Appellant. Appeal from the United States District Court for the District of Maryland, at Baltimore. Paula Xinis, District Judge. (1:18-cv-03309-PX) Submitted: March 31, 2026 Decided: April 9, 2026 Before WILKINSON, KING, and THACKER, Circuit Judges. Affirmed in part and dismissed in part by unpublished per curiam opinion. Beckie R. Boddie, Appellant Pro Se. Unpublished opinions are not binding precedent in this circuit.
PER CURIAM: Beckie Boddie appeals the district court's letter order striking her Fed. R. Civ. P. 60(b)(4) motion because she was not a party to the action in which her motion was filed. * Boddie complains that the district court denied her right to be heard, and she seeks to challenge the court's orders establishing a redress plan for fraud victims. We construe Boddie's motion as a request to intervene in the district court proceedings. We discern no abuse of discretion in the court's refusal to allow Boddie to intervene. See Gould v. Alleco, Inc., 883 F.2d 281, 284 (4th Cir. 1989) (providing standard of review). As for Boddie's challenge to the redress plan, "[g]enerally, nonparties to proceedings in the district court may not appeal from a district court's judgment." Sky
Cable, LLC v. DIRECTV, Inc., 886 F.3d 375, 384 (4th Cir. 2018). "A limited exception
arises if a nonparty has an interest in the litigation and actively participated in the particular stage of district court proceedings that is challenged on appeal." Id.; see Doe v. Pub.
Citizen, 749 F.3d 246, 259 (4th Cir. 2014) (describing exception as "nonparty appellate
standing"). Here, Boddie did not actively participate in the district court proceedings, so she lacks nonparty appellate standing. Accordingly, we affirm the denial of Boddie's request to intervene, and we dismiss the remainder of the appeal. We dispense with oral argument because the facts and legal
Boddie has filed motions for a stay, for injunction pending appeal, to supplement * the record, and to address delay in the transmittal of the record. We deny each motion. 2
contentions are adequately presented in the materials before this court and argument would not aid the decisional process.
AFFIRMED IN PART, DISMISSED IN PART
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