Tiffany Locus v. Zachariah Ross - Appeal of Dismissal

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 Tiffany Locus's case for lack of jurisdiction. The court found that Locus failed to challenge the basis for the dismissal in her informal brief, thereby forfeiting appellate review.

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What changed

The Fourth Circuit Court of Appeals has affirmed the district court's decision to dismiss Tiffany Locus's civil action and associated motions for injunctive relief. The dismissal was based on a lack of jurisdiction, stemming from a state-court custody dispute. The appellate court's review was limited to the issues raised in Locus's informal brief, which did not challenge the grounds for the district court's disposition, leading to the forfeiture of appellate review.

This decision means the district court's order stands, and Locus's case is concluded at this appellate level. The court also granted Locus's motions to seal certain documents containing confidential information and denied other pending motions, including those for expedited consideration and injunctive relief. No further action is required from regulated entities as this is a specific case appeal.

Source document (simplified)

UNPUBLISHED UNITED STATES CO URT OF APPEALS FOR THE FOURTH C IRCUIT No. 25-2345 TIFFANY LOCUS, Plaintiff - Appellant, v. ZACHARIAH ROSS, Defendant - Appellee. Appeal from the Unit ed States Distri ct Court for the Eastern District of Virginia, at Alexandria. Patricia Tolliver Gile s, District Judge. (1: 25 - cv -01620- PTG -IDD) 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. Tiffany Locus, Appella nt Pro Se. Jason F. Zell man, SUROVELL IS AACS & LEV Y, PLC, Fairfax, Virginia, for A ppellee. Unpublished opinions are not binding prec edent in this circuit.

2 PER CURIAM: Tiffany Locus appeal s the district c ourt’s order dism issing for lack of jurisdiction Locus’ civil action and various associ ated motions for injunctive relief as related to a state - court custody dispu te. On appeal, we con fine our revie w to the issu es raised in the informal brief. See 4th Cir. R. 34(b). Because Locu s’ informal brief does not challenge the basis for the district court’s dispositio n, she has for feited appellate review of the appealed -from order. * See Jackson v. Lightsey, 775 F.3d 1 70, 177 (4th Cir. 2014) (“ The informal brief is an important document; under Fo urth Circuit rules, our r eview is limited to issue s preserved in that brief. ”). Accordingly, we af firm the district cou rt’s order. We dispense with or al argument because the facts and legal c ontentions are adequately presented in the material s before this court and argume nt would not aid th e decisional process. AFFIRMED * We grant Locus’ motions to seal the proffered appellate docum ents containing confidential informatio n regarding the parties’ children. W e deny as moot Locus’ motion s to expedite our conside ration of this appeal a nd Defendant’s motio n for access to the sealed documents, and deny all other pending motions for injunctive relief, to file ex parte documents, and for oth er miscellaneous relief.