Morris v. HUD — Fourth Circuit upheld dismissal of the civil-rights action and denial of leave to amend

Case
Deborah Morris and Arnell Mason v. United States Department of Housing & Urban Development, et al.
Court
U.S. Court of Appeals for the Fourth Circuit
Judge
J. Harvie Wilkinson III (Ronald Reagan, 1984); James A. Wynn Jr. (Barack Obama, 2010); Pamela Harris (Barack Obama, 2014)
Date Decided
October 20, 2026
Docket No.
26-1880
Topics
Civil Rights; Pleading Requirements; Leave to Amend; Appellate Procedure
Source
Read the full opinion

Background

Deborah Morris and Arnell Mason brought a civil-rights action against the U.S. Department of Housing and Urban Development, federal and Baltimore housing officials and agencies, and several private development and property-management entities. The opinion does not describe the underlying allegations.

The U.S. District Court for the District of Maryland dismissed the action under Federal Rules of Civil Procedure 8(a)(2) and 12 and denied the plaintiffs’ motion to amend. Morris and Mason appealed.

The Court’s Holding

In an unpublished per curiam opinion, the Fourth Circuit affirmed. After reviewing the record, the panel found no reversible error in the district court’s rationale for dismissing the action and denying leave to amend.

The court denied as moot the appellants’ motions for an expedited decision and for leave to supplement that motion. It also denied their motion for summary reversal and other relief. The panel decided the appeal without oral argument because the written materials adequately presented the facts and legal issues and argument would not aid the decisional process.

Key Takeaways

  • The Fourth Circuit affirmed the dismissal under Rules 8(a)(2) and 12.
  • The court also left intact the denial of the plaintiffs’ motion to amend.
  • The decision is unpublished and is not binding precedent in the Fourth Circuit.

Why It Matters

The ruling ends this appeal without disturbing the district court’s dismissal or its refusal to permit an amended pleading. Because the Fourth Circuit adopted the district court’s rationale without further analysis, the appellate opinion itself provides limited additional guidance on the pleading defects or the basis for denying amendment.

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