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Stephanie Adcock v. Durham County - Case Dismissed Without Prejudice

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Summary

The US District Court for the Middle District of North Carolina adopted a Magistrate Judge's Memorandum Opinion and Recommendation dated March 31, 2026. The Court granted Durham County's Motion to Dismiss after finding it lacks subject-matter jurisdiction over claims arising from state court judgments and that remaining allegations fail to state a claim upon which relief may be granted. Plaintiff's Motion for Leave to Amend the Original Complaint was denied for futility. The action was dismissed without prejudice.

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GovPing monitors US District Court MDNC Docket Feed for new courts & legal regulatory changes. Every update since tracking began is archived, classified, and available as free RSS or email alerts — 8 changes logged to date.

What changed

The Court adopted the Magistrate Judge's Recommendation filed March 31, 2026, granting Defendants' Motion to Dismiss and denying Plaintiff's Motion for Leave to Amend. The dismissal was entered without prejudice, meaning Plaintiff may potentially refile if she can cure the jurisdictional defects identified by the Magistrate. Because no parties filed objections to the Recommendation within the April 14, 2026 deadline, the Court reviewed only for clear error under Diamond v. Colonial Life standard.

For parties filing federal claims that may implicate state court judgments, this ruling reinforces the importance of establishing clear federal subject-matter jurisdiction before filing. Litigants should ensure their complaints identify specific federal statutory or constitutional bases for jurisdiction, not merely assert injuries arising from state proceedings.

Archived snapshot

Apr 25, 2026

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April 24, 2026 Get Citation Alerts Download PDF Add Note

Stephanie Adcock v. Durham County

District Court, M.D. North Carolina

Trial Court Document

IN THE UNITED STATES DISTRICT COURT
FOR THE MIDDLE DISTRICT OF NORTH CAROLINA

STEPHANIE ADCOCK,

Plaintiff,
1:25-CV-6-DAB-LPA
v.

DURHAM COUNTY,

Defendant.

ORDER
This matter is before the Court for review of the Memorandum Opinion and
Recommendation filed on March 31, 2026. 3/31/26 Memorandum Opinion and
Recommendation of United States Magistrate Judge (D.E. 18). The Magistrate Judge
recommends granting Defendants’ Motion to Dismiss (D.E. 9) because the Court
lacks subject-matter jurisdiction over the Complaints’ claims arising from state court
judgments, and the remaining allegations fail to state a claim upon which relief may
be granted and denying Plaintiff’s Motion for Leave to Amend the Original
Complaint (D.E. 14) for futility. The deadline for objections passed on April 14,
2026, and no parties have objected to the Recommendation.
Because there are no objections, the Court “must ‘only satisfy itself that there
is no clear error on the face of the record in order to accept the recommendation.’”
Diamond v. Colonial Life & Acc. Ins. Co., 416 F.3d 310, 315 (4th Cir. 2005) (quoting
Fed. R. Civ. Proc. 72 advisory committee’s note). This Court has accordingly
reviewed the Recommendation and concludes it contains no clear error.
Accordingly, it is ORDERED that the Magistrate Judge’s Recommendation,
3/31/26 Memorandum Opinion and Recommendation, is ADOPTED, Defendants’
Motion to Dismiss is GRANTED and Plaintiff’s Motion for Leave to Amend the
Original Complaint is DENIED. Further, this action is DISMISSED WITHOUT
PREJUDICE.
A Judgment dismissing this action will be entered contemporaneously with
this Order.
This the 24th day of April, 2026.

/s/ David A. Bragdon
United States District Judge

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Last updated

Classification

Agency
USDC MDNC
Filed
April 24th, 2026
Instrument
Enforcement
Branch
Judicial
Legal weight
Binding
Stage
Final
Change scope
Minor
Docket
1:25-cv-00006

Who this affects

Applies to
Government agencies Criminal defendants
Industry sector
9211 Government & Public Administration
Activity scope
Civil litigation Motion to dismiss Subject-matter jurisdiction
Geographic scope
US-NC US-NC

Taxonomy

Primary area
Judicial Administration
Operational domain
Legal
Topics
Civil Rights

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