US v. Tito Knox - Appeal from South Carolina District Court Affirmed

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 denying Tito Knox's motion to terminate conditional release and supervision. The court found that Knox 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 has affirmed the district court's order denying Tito Knox's motion to terminate his conditional release and supervision, as provided for by 18 U.S.C. § 4243(f). The appellate court's review was limited to the issues raised in Knox's informal brief, and because the brief did not challenge the basis of the district court's decision, Knox forfeited appellate review of the order. The court cited Jackson v. Lightsey for the principle that review is limited to issues preserved in the informal brief.

This decision has no immediate compliance implications for regulated entities as it pertains to a specific criminal appeal. However, it serves as a reminder of the procedural requirements for appeals within the Fourth Circuit, particularly the importance of adequately preserving issues in informal briefs to ensure appellate review. The ruling affirms the district court's order, meaning Knox's conditional release and supervision remain in effect as previously determined.

Source document (simplified)

UNPUBLISHED UNITED STATES COURT OF AP PEALS FOR THE FOURTH CIRCUIT No. 25 - 6906 UNITED ST ATES OF AMER ICA, Plaintiff - Appellee, v. TITO LEMO NT KNOX, Defendant - Appellant. Appeal from the United States District Court for the District of South Carolin a, at Greenville. Donald C. Coggins, Jr., District J udge. (6:06 - cr - 00269 - DCC -1) Submitted: February 26, 202 6 Decided: March 3, 2026 Before NIEMEYER a nd QUATTL EBAUM, Circuit Jud ges, and FLOYD, Senior Circu it Judge. Affirmed by unpublished per curiam opinion. Tito Lemont Knox, Appellant Pro Se. Maxw ell B. Cauthen, III, Assistant United States Attorney, OFFICE O F THE UNITE D STATES AT TORNEY, Greenvill e, South Ca rolina, for Appellee. Unpublished opinions are not binding p recedent in this circuit.

2 PER CURIAM: Tito Lemo nt Knox appeals the district court’s October 8, 2025, opinion and order denying K nox’s moti on to terminat e his conditional release and supervision, provided fo r by 18 U.S.C. § 4243(f). On appeal, we confine our review to the issues raised in the informal brief. See 4 th Cir. R. 34(b). Because Knox’s informal brief does not challenge the basis for the district court’s d isposition, he has forfeited appellate review of th e court’s order. See Jackson v. Lightsey, 775 F.3d 17 0, 177 (4t h Cir. 201 4) (“ Th e informal brief is an important document; under Fourth Circuit rules, our review is limited to issues preserved in that brief.”). Accordingly, w e affirm the appealed - from order. We dispense with oral argument becau se the facts and legal contentions are adequately presented in the materials before this court and argument would not aid the decisional process. AFFIRMED