Brown v. Washington University - Appeal Affirmation

4th Circuit Daily Opinions

Filed February 23rd, 2026

Detected February 24th, 2026

Summary

The Fourth Circuit Court of Appeals affirmed a district court's decision to dismiss a civil complaint without prejudice for lack of personal jurisdiction. The unpublished opinion noted that unpublished opinions are not binding precedent in the circuit.

View original document View source feed page

What changed

The United States Court of Appeals for the Fourth Circuit has affirmed the district court's dismissal of Allison Sydney Brown's civil complaint. The dismissal was based on a lack of personal jurisdiction. The appellate court reviewed the record and found no reversible error, denying Brown's motion to amend the caption and affirming the lower court's order. This decision is an unpublished opinion and therefore does not constitute binding precedent within the Fourth Circuit.

This ruling means the plaintiff's case, as filed, is concluded at the appellate level. For legal professionals, this case serves as an example of how appellate courts handle appeals concerning jurisdictional dismissals. As an unpublished opinion, it does not create new legal obligations or require specific actions from regulated entities, but it reinforces existing procedural standards regarding personal jurisdiction.

Source document (simplified)

UNPUBLISHED UNITED STATES COURT OF AP PEALS FOR THE FOURTH CIRCUIT No. 25 - 1887 ALLISON SYDNEY BR OWN, Plaintiff - Appellant, v. THE WASHINGTON UNIVERSITY, Individually and in their official capacity; ELIZABETH WALSH, Individually and in their official capacity; ADRIENNE DAVIS, Individually and in their official capacity; CARRIE BURNS, Individually and in their official capacity; RUSSELL OSGOOD, In dividually and in their official capacity; ROBERT WILD, Individually and in their official capacity; DARRELL HUDSON, Individually and in their official capacity; DEANNA WENDLER - MODDE, Individually and in their official capacity; NICOLE GORE, Individually and in their official capacity; PEGG IE SMITH, Individually and in their official capacity; MARK KAMIMURA - JIMENEZ, Individually and in th eir official capacity; ELIZABETH KATZ, Individually and in their official cap acity; ANGELA SMITH, Individually and in their official cap acity, Defendants - Appellees. Appeal from the United States District C ourt for the District of M aryland, at Greenbelt. Theodore D. Chuang, District Judge. (8:24 - cv - 03198 - TDC) Submitted: February 19, 202 6 Decided: February 23, 2026 Before WYNN and HARRIS, Circuit Judges, and TRAXLER, Senior Circuit Judge. Affirmed by unpublished per curiam opinion.

2 Allison Sydney Brown, Appellant Pro Se. A licia Marie Swartz Pitts, SAUL EWING LLP, Baltimore, Maryland, for Appellees. Unpublished opinions are not binding p recedent in this circuit.

3 PER CURIAM: Allison Sydne y Brown appeals the d istrict court’s order dismissing her civil complaint without prejudice for lack of p ersonal jurisdiction. We have reviewed the record and find no reversible error. Accordingly, we deny Brown ’s second motion to amend the caption and affirm the district court’s order. Brown v. The Wash. U niv., No. 8:24 - cv - 03198 - TDC (D. Md. A ug. 1 & 12, 2025). W e dispense with oral argumen t because the facts and legal contentions are adeq uately presented in the materials before this court and argument would not aid the decisional process. AFFIRMED