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Fourth Circuit Denies Natalie Tao's Mandamus Petition, February 18

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Summary

The Fourth Circuit denied Natalie A. Tao's petition for writ of mandamus on February 18, 2026. The court found that dismissal of her voluntary Chapter 13 petition under 11 U.S.C. § 521(i)(1) rendered most of her requested relief moot, and that mandamus relief is unavailable as a substitute for appeal. Her motion for a stay was also denied as moot. This unpublished per curiam opinion is not binding precedent in this circuit.

“Mandamus relief is a drastic remedy and should be used only in extraordinary circumstances.”

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GovPing monitors US Bankruptcy Court DMD Docket Feed for new courts & legal regulatory changes. Every update since tracking began is archived, classified, and available as free RSS or email alerts — 2 changes logged to date.

What changed

The Fourth Circuit denied Natalie A. Tao's petition for writ of mandamus on February 18, 2026, finding that dismissal of her voluntary Chapter 13 petition pursuant to 11 U.S.C. § 521(i)(1) rendered moot much of the relief she sought. The court held that mandamus relief is unavailable when it would serve as a substitute for appeal, and Tao failed to demonstrate a clear right to the requested relief. Her motion for stay of collection or enforcement proceedings was denied as moot.

Affected parties in similar bankruptcy proceedings should note that mandamus is a drastic remedy reserved for extraordinary circumstances and may not be used to circumvent the normal appellate process. Pro se filers seeking mandamus relief must demonstrate both a clear and indisputable right to the relief sought and the absence of adequate alternative means to obtain it.

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Apr 24, 2026

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In re: NATALIE A. TAO, f/k/a Natalie Morgan-Tao, f/k/a Natalie Morgan Tao, formerly doing business as Quality Care Daycare at BUP LLP-SSM, a/k/a Quality Care DayCare at BUP, LLP

United States Bankruptcy Court, D. Maryland

Trial Court Document

UNPUBLISHED

UNITED STATES COURT OF APPEALS
FOR THE FOURTH CIRCUIT

No. 25-2096

In re: NATALIE A. TAO, f/k/a Natalie Morgan-Tao, f/k/a Natalie Morgan Tao, formerly
doing business as Quality Care Daycare at BUP LLP-SSM, a/k/a Quality Care DayCare at
BUP, LLP,

Petitioner.

On Petition for Writ of Mandamus to the United States Bankruptcy Court for the District
of Maryland, at Baltimore. (25-14490)

Submitted: January 30, 2026 Decided: February 18, 2026

Before KING, RICHARDSON, and QUATTLEBAUM, Circuit Judges.

Petition denied by unpublished per curiam opinion.

Natalie A. Tao, Petitioner Pro Se.

Unpublished opinions are not binding precedent in this circuit.
PER CURIAM:
Natalie A. Tao petitions for a writ of mandamus in relation to her voluntary Chapter

13 petition in bankruptcy, seeking an order directing the bankruptcy court to disqualify the
Trustee; require the Trustee to credit certain plan payments and preserve and reconstruct
certain documents; provide ADA-compliant access to all proceedings; recover certain
assets; prohibit certain parties from participating in proceedings; and abstain from
retaliating against her. Tao further requests that this court stay any collection or
enforcement proceedings pending the resolution of this petition.

Mandamus relief is a drastic remedy and should be used only in extraordinary
circumstances. Cheney v. U.S. Dist. Ct., 542 U.S. 367, 380 (2004); In re Murphy-Brown,
LLC, 907 F.3d 788, 795 (4th Cir. 2018). Further, mandamus relief is available only when
the petitioner “has a clear and indisputable right to” the relief she seeks and “has no other
adequate means . . . to attain the desired relief.” In re Moore, 955 F.3d 384, 388 (4th Cir.

2020) (citation modified). Our review of the bankruptcy court’s docket leads us to
conclude that the dismissal of Tao’s voluntary Chapter 13 petition pursuant to 11 U.S.C.
§ 521 (i)(1) renders moot much of the relief Tao seeks. The remaining relief Tao seeks is
not available by way of mandamus because mandamus may not be used as a substitute for
appeal, see In re Lockheed Martin Corp., 503 F.3d 351, 353 (4th Cir. 2007), and Tao has

not demonstrated a clear right to the relief sought.
Accordingly, we deny the petition for a writ of mandamus and deny as moot Tao’s
motion for a stay. 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.

PETITION DENIED

Citations

11 U.S.C. § 521(i)(1) statute rendering petition moot
542 U.S. 367 mandamus extraordinary circumstances standard

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Last updated

Classification

Agency
Fourth Circuit
Filed
February 18th, 2026
Instrument
Enforcement
Branch
Judicial
Legal weight
Binding
Stage
Final
Change scope
Minor
Document ID
No. 25-2096
Docket
25-14490

Who this affects

Applies to
Criminal defendants
Industry sector
9211 Government & Public Administration
Activity scope
Mandamus petition Chapter 13 bankruptcy Trustee disqualification
Geographic scope
United States US

Taxonomy

Primary area
Judicial Administration
Operational domain
Legal
Topics
Bankruptcy

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