James Ray, Jr. v. J. Hanak

• Court: Court of Appeals for the Fourth Circuit
• Decided: January 28, 2026
• Docket: 25-1819
• Status: Unpublished

Opinion

USCA4 Appeal: 25-1819 Doc: 10 Filed: 01/28/2026 Pg: 1 of 3

UNPUBLISHED

UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT

No. 25-1819

JAMES SHELTON RAY, JR.,

Plaintiff - Appellant,

v.

J. H. HANAK, Officer; W. T. SPENCER, Sergeant; P. J. HOWARD, Officer,

Defendants - Appellees.

Appeal from the United States District Court for the Eastern District of North Carolina, at Raleigh. Richard E. Myers, II, Chief District Judge. (5:22-cv-00379-M-RN)

Submitted: January 22, 2026 Decided: January 28, 2026

Before AGEE, RICHARDSON, and HEYTENS, Circuit Judges.

Affirmed by unpublished per curiam opinion.

James Shelton Ray, Jr., Appellant Pro Se. Jacob Holmes Wellman, TEAGUE, CAMPBELL, DENNIS & GORHAM, LLP, Raleigh, North Carolina, for Appellee.

Unpublished opinions are not binding precedent in this circuit. USCA4 Appeal: 25-1819 Doc: 10 Filed: 01/28/2026 Pg: 2 of 3

PER CURIAM:

James Shelton Ray, Jr., appeals the district court’s orders accepting the

recommendations of the magistrate judge and denying relief in his 42 U.S.C. § 1983 action.

Limiting our review to the issues raised in Ray’s informal brief, see 4th Cir. R. 34(b); see

also Jackson v. Lightsey, 775 F.3d 170, 177 (4th Cir. 2014) (“The informal brief is an

important document; under Fourth Circuit rules, our review is limited to issues preserved

in that brief.”), we have reviewed the record and the district court’s various rulings and

find no reversible error. Particularly, as to the district court’s order dismissing many of

Ray’s claims pursuant to 28 U.S.C. § 1915(e), we discern no error in the court’s

determination that Ray’s objections to the magistrate judge’s recommendation were not

specific to the particularized legal recommendations, so appellate review of that order is

foreclosed. See Martin v. Duffy, 858 F.3d 239, 245 (4th Cir. 2017) (holding that, “to

preserve for appeal an issue in a magistrate judge’s report, a party must object to the finding

or recommendation on that issue with sufficient specificity so as reasonably to alert the

district court of the true ground for the objection” (citation modified)). As to the district

court’s order granting summary judgment to the remaining defendants on Ray’s Fourth

Amendment unlawful arrest claim, we discern no reversible error in the court’s

determination that officers had probable cause to arrest him. And finally, we discern no

abuse of discretion in either the district court’s decision to quash Ray’s subpoena or to

decline his request to add a defendant to his action.

Accordingly, we affirm the district court’s judgment. Ray v. Hanak, No. 5:22-cv-

00379-M-RN (E.D.N.C. June 20, 2025). We dispense with oral argument because the facts

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and legal contentions are adequately presented in the materials before this court and

argument would not aid the decisional process.

AFFIRMED