Charles v. Buffaloe - Habeas Corpus Appeal

4th Circuit Daily Opinions

Filed April 2nd, 2026

Detected April 3rd, 2026

Summary

The Fourth Circuit dismissed James Benjamin Charles's appeal seeking review of the Western District of North Carolina's denial of his 28 U.S.C. § 2254 habeas corpus petition. The court denied a certificate of appealability and dismissed the appeal, finding Charles failed to demonstrate that reasonable jurists could find the district court's procedural ruling debatable or that he stated a debatable constitutional claim.

View original document View source feed page

What changed

The Fourth Circuit reviewed Charles's appeal from the district court's denial of his § 2254 habeas petition challenging his state criminal conviction. The court applied the standard from 28 U.S.C. § 2253(c)(2), requiring a substantial showing of denial of a constitutional right. When the district court denies relief on procedural grounds—as here—a prisoner must demonstrate both that the procedural ruling is debatable and that the petition states a debatable constitutional claim. The court independently reviewed the record and concluded Charles did not meet this burden.

Charles, proceeding pro se, sought to appeal the denial of his habeas petition to the Fourth Circuit. The court dismissed the appeal and denied the certificate of appealability required under § 2253(c)(1)(A) for such appeals. This procedural dismissal means Charles cannot proceed with his appeal absent further court action. No oral argument was held. Pro se prisoners seeking federal review of state convictions must satisfy these certificate of appealability requirements to proceed.

Source document (simplified)

UNPUBLISHED

UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT

No. 25-6067

JAMES BENJAMIN CHARLES, Petitioner - Appellant,

EDDIE M. BUFFALOE, JR., f/k/a The State of North Carolina, Secretary of North Carolina Department of Public Safety (Previously listed as Erik A. Hooks), Respondent - Appellee. Appeal from the United States District Court for the Western District of North Carolina, at Asheville. Martin K. Reidinger, Chief District Judge. (1:20-cv-00196-MR) Submitted: March 10, 2026 Decided: April 2, 2026 Before HARRIS and THACKER, Circuit Judges, and KEENAN, Senior Circuit Judge. Dismissed by unpublished per curiam opinion. James Benjamin Charles, Appellant Pro Se. Unpublished opinions are not binding precedent in this circuit.

PER CURIAM: James Benjamin Charles seeks to appeal the district court's orders denying relief on his 28 U.S.C. § 2254 petition. The orders are not appealable unless a circuit justice or judge issues a certificate of appealability. See 28 U.S.C. § 2253(c)(1)(A). A certificate of appealability will not issue absent "a substantial showing of the denial of a constitutional right." 28 U.S.C. § 2253(c)(2). When the district court denies relief on the merits, a prisoner satisfies this standard by demonstrating that reasonable jurists could find the district court's assessment of the constitutional claims debatable or wrong. See Buck v.

Davis, 580 U.S. 100, 115-17 (2017). When the district court denies relief on procedural

grounds, the prisoner must demonstrate both that the dispositive procedural ruling is debatable and that the petition states a debatable claim of the denial of a constitutional right. Gonzalez v. Thaler, 565 U.S. 134, 140-41 (2012) (citing Slack v. McDaniel, 529 U.S. 473, 484 (2000)). We have independently reviewed the record and conclude that Charles has not made the requisite showing. Accordingly, we deny a certificate of appealability and dismiss the appeal. 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.

DISMISSED