Background
Brad R. Johnson, proceeding pro se, filed a civil complaint against PennyMac Loan Services, LLC, Standard Guaranty Insurance Company, and Assurant Inc. The District of South Carolina adopted a magistrate judge’s recommendation and dismissed the complaint on res judicata grounds.
Johnson moved under Federal Rule of Civil Procedure 59(e) to alter or amend the dismissal order. After the district court denied that motion, Johnson appealed both the dismissal and the denial of postjudgment relief.
The Court’s Holding
The Fourth Circuit affirmed both district court orders. After reviewing the parties’ appellate arguments, the record, and the relevant authorities, the panel concluded that there was no reversible error.
The unpublished per curiam opinion did not separately analyze the elements of res judicata or the standards governing Rule 59(e). The court also dispensed with oral argument because it found the written materials adequate and concluded that argument would not aid the decisional process.
Key Takeaways
- The Fourth Circuit left intact the dismissal of Johnson’s complaint on res judicata grounds.
- The court also affirmed the denial of Johnson’s Rule 59(e) motion to alter or amend the dismissal order.
- The opinion is unpublished and states that unpublished opinions are not binding precedent in the Fourth Circuit.
Why It Matters
The decision ends Johnson’s appeal without disturbing either challenged district court ruling. Because the Fourth Circuit provided only a no-reversible-error determination, the opinion offers no detailed appellate analysis of res judicata or Rule 59(e).