Henson v. City of Virginia Beach - Civil Rights Appeal

4th Circuit Daily Opinions

Filed March 2nd, 2026

Detected March 3rd, 2026

Summary

The Fourth Circuit Court of Appeals affirmed a district court's dismissal of a pro se appellant's amended complaint. The court found no reversible error in the dismissal of claims brought under 42 U.S.C. §§ 1983, 1985, and 1986, and the Americans with Disabilities Act. Motions to supplement the record were denied.

View original document View source feed page

What changed

The Fourth Circuit Court of Appeals has affirmed the district court's decision to dismiss Craig M. Henson's amended complaint. The complaint, filed under 42 U.S.C. §§ 1983, 1985, and 1986, and the Americans with Disabilities Act, was dismissed pursuant to 28 U.S.C. § 1915(e)(2). The appellate court reviewed the record and found no reversible error, thus upholding the lower court's ruling. Additionally, the court denied Mr. Henson's motions to supplement the record.

This unpublished opinion serves as a reminder that unpublished opinions are not binding precedent in the Fourth Circuit. For regulated entities, this means the outcome of this specific case does not establish new legal standards. However, it reinforces the importance of proper legal standing and adherence to procedural requirements when filing complaints, particularly those involving civil rights and disability law. No specific compliance actions are required for entities based on this ruling, as it pertains to an individual's appeal and does not introduce new regulatory obligations.

Source document (simplified)

UNPUBLISHED UNITED STATES CO URT OF APPEALS FOR THE FOURTH C IRCUIT No. 25-2159 CRAIG M. HENSON, Plaintiff - Appellant, v. CITY OF VIRGINIA BEACH; PAT RICK DUHANEY, City Manager, in his official capacity, 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. (2:23- cv -00628-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 Unpublished opinions are not binding prec edent in this circuit.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. §§ 1983, 1985, and 1986 and the Americans with Disabilities Act under 28 U.S.C. § 1915(e)(2). * We have reviewed the record and discer n no reversible error. Accordingly, we affirm the distric t court’s or der. Henson v. City of Va. Beach, No. 2:23- cv -00628-RBS-LRL (E.D. Va. July 1 4, 2025). We dispense with oral argument because the f acts and legal co ntentions are adequately presented in the mater ials before this court and ar gument would not aid the decisional proces s. AFFIRMED * Henson filed motions t o supplement the re cord. We deny those motions.