Love v. McAdams — Fourth Circuit affirmed dismissal of the remaining First Amendment claim

Case
Arthur M. Love v. Steven McAdams
Court
U.S. Court of Appeals for the Fourth Circuit
Judge
Harris; Rushing; Keenan
Date Decided
September 17, 2026
Docket No.
26-1066
Topics
First Amendment; Section 1983; Motion to Dismiss; Civil Rights
Source
Read the full opinion

Background

Arthur M. Love sued Steven McAdams, the State of Maryland, and several other defendants, asserting constitutional claims. In an earlier appeal, the Fourth Circuit affirmed the dismissal of Love’s claims against Maryland and the other defendants, with certain official-capacity dismissals modified to be without prejudice.

That earlier decision vacated the dismissal of Love’s 42 U.S.C. § 1983 claim against McAdams and remanded it for further proceedings. On remand, the district court granted McAdams’ motion to dismiss the remaining claim, which alleged a violation of Love’s First Amendment rights. Love appealed pro se.

The Court’s Holding

The Fourth Circuit affirmed the district court’s dismissal of the remaining § 1983 claim against McAdams. After reviewing the record, the panel concluded that the district court committed no reversible error.

The unpublished per curiam opinion did not provide additional substantive analysis of the First Amendment claim. The court also granted Love’s motion to file his informal reply brief out of time and decided the appeal without oral argument.

Key Takeaways

  • The Fourth Circuit affirmed dismissal of Love’s remaining First Amendment claim against McAdams.
  • The court found no reversible error but did not elaborate on the district court’s reasoning.
  • The unpublished decision is not binding precedent in the Fourth Circuit.

Why It Matters

The ruling ends the remanded portion of Love’s case at the appellate level by upholding dismissal of the sole claim left against McAdams. Because the opinion offers no detailed merits analysis and is unpublished, its value as guidance for future First Amendment or § 1983 litigation is limited.

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