Winslow v. Commonwealth of Virginia - Civil Action Appeal

4th Circuit Daily Opinions

Filed February 20th, 2026

Detected February 21st, 2026

Summary

The Fourth Circuit Court of Appeals affirmed a district court's order dismissing a civil action for lack of subject matter jurisdiction and denying a motion for injunctive relief. The unpublished opinion noted that such opinions are not binding precedent.

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What changed

The Fourth Circuit Court of Appeals issued an unpublished per curiam opinion affirming the district court's dismissal of Erica M. Allen Winslow's civil action due to a lack of subject matter jurisdiction and the denial of her motion for injunctive relief. The court found no reversible error in the lower court's decision and denied the appellant's motion for leave to file an amended informal brief. The case, Winslow v. Commonwealth of Va. Div. of Child Support Enf't, originated from the Eastern District of Virginia.

As this is an unpublished opinion, it does not constitute binding precedent within the Fourth Circuit. Regulated entities and legal professionals involved in similar civil actions should note that the appellate court upheld the dismissal based on jurisdictional grounds. No specific compliance actions are required for entities not directly involved in this case, but it serves as an example of how such appeals are handled and the potential outcomes when subject matter jurisdiction is challenged.

Source document (simplified)

UNPUBLISHED UNITED STATES CO URT OF APPEALS FOR THE FOURTH C IRCUIT No. 25-1817 ERICA M. ALLEN WI NSLOW, Plaintiff - Appellant, v. COMMONWEALTH OF VIRGINIA DIVISION OF C HILD SUPPORT ENFORCEMENT; F AIRFAX COUNTY DIVISION OF CHI LD SUPPORT ENFORCEMENT; SE AN CHARLES WINS LOW, Defendants - Appell ees. Appeal from the Unit ed States Distri ct Court for the Eastern District of Virginia, at Alexandria. Patricia Tolliver Gile s, District Judge. (1:2 5- cv -00251- PTG - WB P) Submitted: February 1 0, 2026 Decided: February 20, 2026 Before NIEMEYER, Circuit Judge, and TRA XLER and KEENAN, Senior Circuit Judges. Affirmed by unpublish ed per curiam opini on. Erica M. Allen Winslo w, Appellant Pro Se. Unpublished opinions are not binding prec edent in this circuit.

2 PER CURIAM: Erica M. Allen Wi nslow appeals the distr ict court’s or der dismissing her civil actio n for lack of subject matter jurisdiction and de nying her motion f or injunctive relief. We have reviewed the re cord and discern no reversible erro r. Accor dingly, we deny as unnecessary Winslow’s motion fo r leave to file an amende d informal brief with t he list of issues moved to the firs t page of the brief, an d we affirm the district co urt’s order. Winslo w v. Commonwealth of V a. Div. of Chil d Support Enf ’t, No. 1:2 5- cv -00251- PTG - WBP (E.D. Va. June 20, 2025). We dispense with oral argument because the facts and legal contentions are adequat ely presented in t he materials before this c ourt and argument wo uld not aid the decisional p rocess. AFFIRMED