Henson v. City of Virginia Beach - Appeal Affirmed

4th Circuit Daily Opinions

Filed March 2nd, 2026

Detected March 3rd, 2026

Summary

The Fourth Circuit Court of Appeals affirmed a district court's decision to dismiss a pro se appellant's amended complaint. The appellant alleged violations under 42 U.S.C. §§ 1983, 1985, and 1986, and the Americans with Disabilities Act. The court found no reversible error in the dismissal for failure to state a claim.

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What changed

The Fourth Circuit Court of Appeals has affirmed the district court's dismissal of Craig M. Henson's amended complaint. The complaint, brought under 42 U.S.C. §§ 1983, 1985, and 1986, and the Americans with Disabilities Act, was dismissed for failure to state a claim under 28 U.S.C. § 1915(e)(2). The appellate court reviewed the record and found no reversible error, thus upholding the lower court's decision. Motions to supplement the record and consolidate this appeal were denied.

This decision means the appellant's claims against the City of Virginia Beach Government, MuniCode, and CivicPlus have been definitively rejected at the appellate level. For legal professionals, this case serves as an example of how pro se complaints, particularly those alleging civil rights and disability discrimination, are scrutinized for failure to state a claim. There are no further compliance actions required by regulated entities based on this specific ruling, as it pertains to an individual's appeal.

Source document (simplified)

UNPUBLISHED UNITED STATES CO URT OF APPEALS FOR THE FOURTH C IRCUIT No. 25-2157 CRAIG M. HENSON, Plaintiff - Appellant, v. CITY OF VIRGINIA BEACH GOVERNME NT; MUNICODE; CIVICPLUS, Defendants - Appell ees. Appeal from the Unit ed States Distri ct Court for the Eastern District of Virginia, at Norfolk. Rebecca Bea ch Smith, Senior District Judge. (2:24- cv -00089-RBS-L RL) Submitted: February 2 6, 2026 Decided: March 2, 2026 Before NIEMEYER and QUATTLE BAUM, Circuit Judge s, and FLOYD, Senior Circui t Judge. Affirmed by unpublish ed per curiam opini on. Craig M. Henson, App ellant Pro Se. Unpublished opinions are not binding prec edent in this circuit.

2 PER CURIAM: Craig M. Henson appeals the district court’s order dismissing his amended complaint brought pursuant to 42 U.S.C. §§ 19 83, 1985, and 1986 and the Americans w ith Disabilities Act for fa ilure to state a claim under 28 U.S. C. § 1915(e)(2). * We have reviewed the record and discern no reversible error. Accordingly, we affirm the dist rict court ’s order. Henson v. City of Va. Bea ch Gov’t, No. 2:24- cv -00089-RBS-LRL (E.D. Va. July 1 4, 2025). We dispense wit h oral argument becau se the facts and legal contentions are adequately presente d in the materials before this court and argume nt would not aid the decisional process. AFFIRMED * Henson filed motions to supplement the record and to consoli date this appeal with his appeal pending in No. 25-2159. We deny those motions.