Background
William Parke Custis filed a pro se complaint under 42 U.S.C. § 1983 against attorney Richard S. Phillips in the U.S. District Court for the Eastern District of Virginia. The Fourth Circuit’s brief unpublished opinion does not describe Custis’s allegations or the relief he sought.
The district court dismissed the complaint under the statutory screening provisions in 28 U.S.C. §§ 1915(e)(2)(B) and 1915A. Custis appealed that dismissal to the Fourth Circuit.
The Court’s Holding
In an unpublished per curiam opinion, the Fourth Circuit affirmed the district court’s dismissal. After reviewing the record, the court concluded that there was no reversible error.
The court relied on the district court’s January 29, 2026 order in Custis v. Phillips, No. 3:25-cv-00775-DJN-MRC. It did not provide additional analysis of Custis’s claims or the grounds for dismissal.
Key Takeaways
- The Fourth Circuit affirmed the screening dismissal of Custis’s Section 1983 complaint.
- The panel found no reversible error in the district court’s ruling under 28 U.S.C. §§ 1915(e)(2)(B) and 1915A.
- The court decided the appeal without oral argument and designated its per curiam opinion as unpublished and nonprecedential.
Why It Matters
The decision leaves the district court’s dismissal intact but adds no substantive analysis for future litigants. Because the opinion is unpublished, it is not binding precedent in the Fourth Circuit.