Bolton v. JP Morgan Chase — Fourth Circuit affirmed dismissal without prejudice and denial of reconsideration

Case
Asani Bolton v. JP Morgan Chase
Court
U.S. Court of Appeals for the Fourth Circuit
Judge
King; Benjamin; Berner
Date Decided
October 22, 2026
Docket No.
25-2426
Topics
Civil Procedure; Dismissal; Reconsideration; Appellate Review
Source
Read the full opinion

Background

Asani Bolton filed a civil complaint against JP Morgan Chase in the U.S. District Court for the District of South Carolina. The district court accepted a magistrate judge’s recommendation and dismissed the complaint without prejudice.

Bolton then moved to alter or amend the judgment under Federal Rule of Civil Procedure 59(e). After the district court denied that motion, Bolton appealed both orders to the Fourth Circuit.

The Court’s Holding

The Fourth Circuit affirmed the dismissal and the denial of Bolton’s Rule 59(e) motion. After reviewing the record, the court concluded that the district court had committed no reversible error.

The unpublished per curiam opinion did not provide additional reasoning or describe the complaint’s underlying allegations. The panel also dispensed with oral argument because the written materials adequately presented the facts and legal contentions and argument would not aid the decisional process.

Key Takeaways

  • The Fourth Circuit left intact the dismissal of Bolton’s complaint without prejudice.
  • The court also affirmed the denial of Bolton’s Rule 59(e) motion to alter or amend the judgment.
  • The decision is unpublished and is not binding precedent in the Fourth Circuit.

Why It Matters

The decision resolves Bolton’s appeal but establishes no binding circuit precedent. Because the opinion rests on the absence of reversible error and supplies no substantive analysis, its broader value is limited.

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