Watson v. Deberry - Civil Rights Appeal

4th Circuit Daily Opinions

Filed March 2nd, 2026

Detected March 3rd, 2026

Summary

The Fourth Circuit Court of Appeals affirmed the district court's dismissal of James R. Watson Jr.'s pro se complaint under 42 U.S.C. § 1983. The court found no reversible error in the dismissal without prejudice or the denial of the motion for reconsideration.

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What changed

The Fourth Circuit Court of Appeals has affirmed the district court's decision in Watson v. Deberry, Case No. 4:25-cv-10454-SAL. The appellate court reviewed the record and found no reversible error in the district court's orders, which included accepting a magistrate judge's recommendation to dismiss Watson's 42 U.S.C. § 1983 complaint without prejudice and denying Watson's subsequent motion for reconsideration. The opinion was issued per curiam and designated as unpublished.

As an unpublished opinion, this ruling does not set binding precedent in the Fourth Circuit. For regulated entities, this case represents a routine appellate review of a lower court's procedural decisions in a civil rights complaint. There are no new compliance obligations or deadlines imposed by this decision. The primary implication is for the parties involved, particularly the appellant, James R. Watson Jr., whose legal challenge has been concluded at the appellate level.

Source document (simplified)

UNPUBLISHED UNITED STATES CO URT OF APPEALS FOR THE FOURTH C IRCUIT No. 25-2393 JAMES R. WATSON, JR., Plaintiff - Appellant, v. HON. H. STEVEN DE BERRY; OFFICE OF DISCIPLINARY COU NSEL, Defendants - Appell ees. Appeal from the United States District Cour t for the District of South Carolina, at Florence. Sherri A. Lydon, Distri ct Judge. (4:25- cv - 10454- SAL) Submitted: February 2 6, 2026 Decided: March 2, 2026 Before NIEMEYER and QUATTLE BAUM, Circuit Judges, and FL OYD, Senior Circuit Judge. Affirmed by unpublish ed per curiam opini on. James R. Watson, Jr., Appellant Pro Se. Unpublished opinions are not binding prec edent in this circuit.

2 PER CURIAM: James R. Wa tson, Jr., appeal s the district court’s orders (1) accepting the recommendation of the magistrate judge and dismissing wit hout prejudice Watson’s pro s e 42 U.S.C. § 19 83 complaint, a nd (2) de nying Watson’s m otion for r econsideration. * We have reviewed the record and discern no reversible err or. Accordingly, w e affirm the district court’s order s. Watson v. DeBerry, No. 4:25- cv -10454- SA L (D.S.C., Sep. 23, 2025; Nov. 12, 2025). We dispense wit h oral argument because the facts and legal contentions are adequat ely presented in t he materials before this c ourt and argument wo uld not aid the decisional p rocess. AFFIRMED * The district court ’s dismissal order is a final decision because the cou rt dismissed the complaint “without providing leave to am end.” Britt v. DeJoy, 45 F.4th 790, 796 (4th Cir. 2022) (en banc).