Onaje Seabrook v. Lt. Carter

• Court: Court of Appeals for the Fourth Circuit
• Decided: March 3, 2025
• Docket: 24-6461
• Status: Unpublished

Opinion

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UNPUBLISHED

UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT

No. 24-6461

ONAJE KUDURA SEABROOK,

Plaintiff - Appellant,

v.

LT. CARTER; SGT. MILES PERKINS,

Defendants - Appellees,

and

JANE DOE #3, Health Care Authority; JANE DOE #2, Nurse; JANE DOE #1, Nurse; JANE DOE #4, Nurse,

Defendants.

No. 24-6561

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JANE DOE #3, Health Care Authority; JANE DOE #2, Nurse; JANE DOE #1, Nurse; JANE DOE #4, Nurse,

Appeals from the United States District Court for the District of South Carolina, at Aiken. Richard Mark Gergel, District Judge. (1:23-cv-00007-RMG)

Submitted: February 24, 2025 Decided: March 3, 2025

Before AGEE and WYNN, Circuit Judges, and KEENAN, Senior Circuit Judge.

Vacated and remanded by unpublished per curiam opinion.

Onaje Kudura Seabrook, Appellant Pro Se. Charles Clifford Rollins, RICHARDSON PLOWDEN & ROBINSON, PA, Columbia, South Carolina, for Appellees.

Unpublished opinions are not binding precedent in this circuit.

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PER CURIAM:

Onaje Kudura Seabrook appeals the district court’s order accepting the magistrate

judge’s recommendation and granting summary judgment to Defendants (No. 24-6461),

and the court’s order overruling Seabrook’s objections to the magistrate judge’s

recommendation (No. 24-6561). The magistrate judge recommended granting Defendants’

motion for summary judgment on Seabrook’s 42 U.S.C. § 1983 action because Seabrook

failed to exhaust administrative remedies under the Prison Litigation Reform Act, 42

U.S.C. § 1997e(a), and qualified immunity shielded Defendants. The district court

overruled Seabrook’s April 3 amended objections to the magistrate judge’s report, granted

summary judgment to Defendants, and concluded that objections dated March 13 and filed

after entry of the dismissal order were substantially similar to the April objections; the

court dismissed the March 13 objections as moot. We vacate the district court’s orders and

remand for further consideration.

The district court must “make a de novo determination of those portions of the

[magistrate judge’s] report . . . or recommendations to which objection is made.” 28

U.S.C. § 636(b)(1). To receive de novo review of a magistrate judge’s recommendation

and preserve appellate review of the substance of that recommendation, a party must file

timely, specific objections to the magistrate judge’s report. Elijah v. Dunbar, 66 F.4th 454,

459-60 (4th Cir. 2023); Martin v. Duffy, 858 F.3d 239, 245 (4th Cir. 2017). To qualify as

timely, a party’s objections generally must be filed within 14 days of the service of the

magistrate judge’s report. 28 U.S.C. § 636(b)(1). To qualify as specific, a party’s

objections to a magistrate judge’s recommendations must “reasonably . . . alert the district

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court of the true ground for the objection.” Elijah, 66 F.4th at 460 (internal quotation marks

omitted). We review the timeliness and specificity of a party’s objections de novo. Id. at

461; Solis v. Malkani, 638 F.3d 269, 273 (4th Cir. 2011).

Here, the record discloses that Seabrook timely and specifically objected to the

magistrate judge’s findings that he failed to exhaust his administrative remedies and that

Defendants violated his constitutional rights. Importantly, Seabrook asserted that he gave

his original objections to prison staff on March 13, 2024, and prison staffed stamped the

envelope as received and postmarked the envelope on March 14, 2024, within the extended

deadline for filing objections. See Houston v. Lack, 487 U.S. 266, 276 (1988) (deeming

document filed when given to prison officials for mailing). Seabrook also timely filed

amended objections in April. The district court, however, had received and reviewed only

Seabrook’s April objections before accepting the magistrate judge’s recommendation and

granting summary judgment to Defendants. Once the district court received Seabrook’s

March 13 objections, the court determined that they were substantially similar to the April

objections and concluded that the March 13 objections were therefore moot.

Because the March 13 objections were timely filed under Houston v. Lack and were

not substantially similar to the April objections—and indeed included objections not raised

in the April objections—we conclude that the March 13 objections were not moot and were

properly before the district court. See Elijah, 66 F.4th at 459-60. Accordingly, we vacate

the district court’s orders and remand for consideration of Seabrook’s March 13 objections

in the first instance. We express no opinion on the merits of Seabrook’s claims. We

dispense with oral argument because the facts and legal contentions are adequately

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presented in the materials before this court and argument would not aid the decisional

process.

VACATED AND REMANDED