Background
Ernest Kofi Antwi, proceeding pro se, filed a civil action against CPT Kade A. Williams, PsyD in the United States District Court for the Eastern District of Virginia. Antwi filed a second amended complaint in the action, which was assigned Docket No. 3:25-cv-00567-JAG and assigned to Senior District Judge John A. Gibney, Jr.
The defendant moved to dismiss, and on December 15, 2025, the district court granted the motion, dismissing the action on two independent grounds: failure to state a claim upon which relief can be granted and lack of subject matter jurisdiction. Antwi appealed to the Fourth Circuit and moved to remand the case.
The Court’s Holding
A three-judge panel of the Fourth Circuit—Judges Gregory, Rushing, and Senior Judge Keenan—reviewed the district court’s dismissal order and found no reversible error. The appellate court affirmed the district court’s judgment in full.
The court also denied Antwi’s motion to remand. Because the facts and legal contentions were adequately presented in the appellate materials, the court dispensed with oral argument, finding that argument would not aid the decisional process.
Key Takeaways
- The Fourth Circuit upheld the district court’s dismissal on both failure-to-state-a-claim and subject-matter-jurisdiction grounds.
- The appellate court declined to remand the case.
- The opinion is unpublished and thus not binding precedent in the Fourth Circuit.
Why It Matters
This case illustrates the Fourth Circuit’s deference to district court rulings on jurisdictional and pleading sufficiency grounds. The affirmance underscores the importance of proper pleading and establishing subject matter jurisdiction at the outset of litigation, particularly for pro se litigants, who must still comply with the Federal Rules of Civil Procedure.