Eric Exum v. Lieutenant Donna - Civil Action Appeal

4th Circuit Daily Opinions

Filed March 3rd, 2026

Detected March 4th, 2026

Summary

The Fourth Circuit Court of Appeals affirmed a district court's decision to dismiss a civil action filed by inmate Eric Ricardo Exum. The court found that Exum forfeited appellate review by failing to challenge the district court's ruling in his informal brief.

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What changed

The Fourth Circuit Court of Appeals has affirmed the district court's dismissal of Eric Ricardo Exum's civil action, filed pursuant to Fed. R. Civ. P. 12(b)(6). The appellate court's decision was based on Exum's failure to raise specific challenges to the district court's disposition in his informal brief, thereby forfeiting appellate review under Fourth Circuit rules. The court denied Exum's motion for default judgment and affirmed the lower court's order.

This decision has limited practical implications for regulated entities as it pertains to a specific inmate's civil appeal and does not establish new regulatory requirements or penalties. The unpublished nature of the opinion means it does not serve as binding precedent. Compliance officers should note the procedural requirements for appellate review, particularly the importance of addressing all grounds for appeal in submitted briefs.

Source document (simplified)

UNPUBLISHED UNITED STATES COURT OF AP PEALS FOR THE FOURTH CIRCUIT No. 25 - 6216 ERIC RICARDO EXUM, Plaintiff - Appellant, v. LIEUTENANT DONNA; SERGEAN T JORDAN; COR RECTIONAL OFFICER II CURTIS; CAPT AIN VENABLE; WARD EN ROBERT DEAN, Defendants - Appellees. Appeal from the United States District Co urt for the District of Mary land, at Baltimore. Julie R. Rubin, District Judge. (1:23 - cv - 028 88 - JRR) Submitted: February 26, 2026 Decided: March 3, 2026 Before NIEMEYER a nd QUATTLEB AUM, Circuit Jud ges, and FLOYD, Senior Circu it Judge. Affirmed by unpublished per curiam opinion. Eric Ricardo Exum, App ellant Pro Se. Brittaney Ferrier, Assis tant Attorney General, OFFICE OF THE ATTORNE Y GENERAL O F MARYLAND, Baltimore, Maryland, for Appellees. Unpublished opinions are not binding p recedent in this circuit.

2 PER CURIAM: Eric Ricardo Exum, a Maryland inm ate, appeals the district court’s ord er dismissing his civil action for failure to state a claim on which relief can be granted, purs uant to Fed. R. Civ. P. 12(b)(6). On appeal, we confin e our review to the issues raised in the informal brief. See 4th Cir. R. 34(b). Because Exum ’s informal brief does not challenge the bas es for the district court’s disposition, he has forfeited appellate review of th e court’s order. See Jackson v. Lightsey, 775 F.3d 170, 177 (4th C ir. 2014) (“The informal brief is an important document; under Fouth Circuit rules, our review is limited to issues preserved in that brief.”). Accordingly, we deny Exum’s motion for defau lt judgment, and we affirm the district court’s order. Exum v. Donna, No. 1:23 - cv - 02888 - JRR (D. Md. Mar. 5, 20 25). We dispense with oral argumen t because the facts and legal contentio ns are adequately presented in the materials befo re this court and argument w ould not aid the decisional process. AFFIRMED