Ralston v. Clarke - Civil Rights Appeal

4th Circuit Daily Opinions

Filed March 3rd, 2026

Detected March 4th, 2026

Summary

The Fourth Circuit affirmed a district court's dismissal of a 42 U.S.C. § 1983 civil action filed by a Virginia inmate. The court found no abuse of discretion in the denial of the inmate's motion for appointment of counsel or in delaying discovery rulings pending a motion to dismiss. The inmate forfeited appellate review by not challenging the district court's disposition in his informal brief.

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What changed

The Fourth Circuit Court of Appeals, in an unpublished per curiam opinion, affirmed the district court's dismissal of Andy Lewis Ralston's 42 U.S.C. § 1983 civil action against former Virginia Department of Corrections officials and correctional staff. The appellate court's review was limited to the issues raised in Ralston's informal brief. The court found no abuse of discretion in the district court's denial of Ralston's motion for appointment of counsel and its decision to delay discovery rulings pending the defendants' motion to dismiss. Because Ralston's informal brief did not otherwise challenge the basis for the district court's disposition, he forfeited appellate review of the court's order.

This decision has limited practical implications as it is an unpublished opinion and therefore not binding precedent in the Fourth Circuit. It reaffirms the importance of adhering to circuit rules regarding informal briefs in appellate proceedings. Regulated entities, particularly those involved in litigation, should ensure all grounds for appeal are clearly articulated in required filings to preserve appellate review. No specific compliance actions or deadlines are imposed by this ruling.

Source document (simplified)

UNPUBLISHED UNITED STATES COURT OF AP PEALS FOR THE FOURTH CIRCUIT No. 25 - 6715 ANDY RALST ON, Plaintiff - Appellant, v. HAROLD W. CLARKE, former Director of the Virginia Department of Corrections; M. DAVIS, Warden, Coffeewood Correctional Center; E. D. SALES, Unit Manager, Coffeewood Correctional Center; K. SOUTTER, ADA and PREA Coordinator, Coffeewood Correctional Center; T. BUTLER, Internal Affairs, Coffeewood Correctional Center; B. LANHAM, Internal Affairs, Co ffeewood Correctional Center; PAUL HAYMES, Special Investigator Unit for th e Virginia Department of Corrections; ROSE DURBIN, PREA Manager, Virginia Department of C orrections; MRS. RUIZ, Grievance Coordinator, Coffeewood Correctional Center; LADUKE, Hearing Officer, Coffeewood Correctional Center; BROWN, Hearing Officer, Coffeewood Correctional Center; MA TTICE, Counselor, Coffeewood Correctional Center; WOLD, Counsel or, Co ffeewood Correctional Center; MS. HILL, Institutional Operations Manager, Co ffeewood Correctional Center; LIEUTENANT WILLIAMS, Coffeewood Correctional Cen ter, Defendants - Appellees. Appeal from the United States District Court for the Western District of V irginia, at Roanoke. James P. Jones, Seni or District Judge. (7:23 - cv - 00716 - JPJ -PMS) Submitted: February 26, 202 6 Decided: March 3, 2026 Before NIEMEYER a nd QUATTLEB AUM, Circuit Judg es, and FLOYD, Senior Circuit Judge.

2 Affirmed by unpublished per curiam opinion. Andy Lewis Ralston, Appellant Pro Se. Unpublished opinions are not binding p recedent in this circuit.

3 PER CURIAM: Andy Lewis Ralston, a Virginia inmate, appeals the district court’s order dismissing his 42 U. S.C. § 1983 civil action. On appeal, we confine our review to the issues raised in the informal brief. See 4th Cir. R. 34(b). We discern no abuse of discretion in the district court’s denial of Ralston’s motion for appointment or its decision to delay discovery rulings pending a decision on Defendants’ motion to dismiss. Because Ralston ’s informal brief does not otherwise challenge the basis for the district co urt’s disposition, he h as forfeited appellate review of the court’s order. See Jackson v. Lightsey, 775 F.3d 17 0, 177 (4th Cir. 2014) (“The informal brief is an importan t document; under Fouth Circuit rules, our review is limited to issues preserved in that brief.”). Accordingly, we affirm the district court’s order. Ralson v. Clarke, No. 7:23 - cv - 00716 - JPJ -PMS (W.D. Va. Aug. 4, 2025). We dispense with oral argument because the facts and legal contentions are adequately presented in the materials befo re this court and argument wou ld not aid the decisional process. AFFIRMED