Abrams-Kelly v. Nissan of North America - Appeal Dismissal

4th Circuit Daily Opinions

Filed February 23rd, 2026

Detected February 24th, 2026

Summary

The Fourth Circuit Court of Appeals affirmed the district court's dismissal of Nicole Abrams-Kelly's complaints for failure to pay filing fees. The court found that the appellant forfeited appellate review by not challenging the basis of the district court's disposition in her informal brief.

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What changed

The United States Court of Appeals for the Fourth Circuit affirmed the district court's dismissal of three civil complaints filed by Nicole Abrams-Kelly against Nissan of North America, GEICO Insurance Claims Department, David Fox (NC AGO), Randy Reid (Federal DOT, NHTSA), and Michael Feiereisel (Modern Automotive). The dismissal was based on the plaintiff's failure to pay the required filing fees.

As this is an unpublished opinion, it does not set binding precedent. The appellate court's review was limited to the issues raised in the appellant's informal brief, which did not challenge the district court's reasoning for dismissal. Therefore, the judgment of the district court is affirmed.

Source document (simplified)

UNPUBLISHED UNITED STATES COURT OF AP PEALS FOR THE FOURTH CIRCUIT No. 25 - 1592 NICOLE AB RAMS - KELLY, P laintiff - Appellant, v. NISSAN OF NORTH AMERICA, Arbitration Specialist - CA; GEICO INSURANCE CLAIMS DEPT., Asst. VP Virginia Beach Regional Office; DAVID FOX, NC AGO, Consumer Pro tection Specialists; RANDY REID, Federal DOT, NHTSA Chief of Defects; MICHAEL FEIEREISEL, Modern Automotive General Counsel, Defendants - Appellees. No. 25 - 1593 NICOLE AB RAMS - KELLY, Plaintiff - Appellant, v. NISSAN OF NORTH AMERICA, Arbitration Specialist - CA; GEICO INSURANCE CLAIMS DEPT., Asst. VP Virginia Beach Regional Office; DAVID FOX, NC AGO, Consumer Pro tection Specialists; RANDY REID, Federal DOT, NHTSA Chief of Defects; MICHAEL FEIEREISEL, General Co unsel for Modern Automotive Network (NC), Defendants - Appellees.

2 No. 25 - 1594 NICOLE AB RAMS - KELLY, Plaintiff - Appellant, v. NISSAN OF NORTH AMERICA, Arbitration Specialist - CA; GEICO INSURANCE CLAIMS DEPT., Asst. VP Virginia Beach Regional Office; DAVID FOX, NC AGO, Consumer Pro tection Specialists; RANDY REID, Federal DOT, NHTSA Chief of Defects; MICHAEL FEIEREISEL, Modern Automotive Network General Counsel, Defendants - Appellees. Appeal s from the United States District Court for the Western District of North Carolina, at Charlotte. Kenneth D. Bell, D istrict Judge. (3:25 - cv - 00090 - KDB - SCR; 3:25 - cv - 00091 - KDB - DCK; 3:25 - cv - 00 092 - KDB - SCR) 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. Nicole Abrams Kelly, Appellant Pro Se. Unpublished opinions are not binding p recedent in this circuit.

3 PER CURIAM: Nicole Abrams - Kelly appeals the district court’s order dismissing without prejudice her complaint s in the und erlying civil actions for failing to pay th e filing fee. On appeal, we confine our review to the issues raised in the informal brief. See 4th Cir. R. 34(b). Because Abrams - Kelly’s informal brief and the supplements thereto do not ch allenge the basis for the district court’s dispositio n, she has forfeited appellate review of the court’s order. See Jackson v. L ightsey, 775 F.3d 170, 177 (4th Cir. 2014) (“The informal brief is an important document; under Fourth Circuit rules, our review is limited to issues preserved in that brief.”). Accordingly, w e affirm the district court’s judgment s. We dispense with oral argument because the facts and legal contentions are adequately presented in the materials befo re this court and argument w ould not aid the decisional process. AFFIRMED