Dennis Forbes v. Warden

USCA4 Appeal: 25-6325 Doc: 9 Filed: 09/23/2025 Pg: 1 of 2 UNPUBLISHED UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT No. 25-6325 DENNIS A. FORBES, Petitioner - Appellant, v. WARDEN, FCI McDowell, Respondent - Appellee. Appeal from the United States District Court for the Southern District of West Virginia, at Bluefield. David A. Faber, Senior District Judge. (1:24-cv-00194) Submitted: September 18, 2025 Decided: September 23, 2025 Before THACKER and BENJAMIN, Circuit Judges, and TRAXLER, Senior Circuit Judge. Affirmed by unpublished per curiam opinion. Dennis A. Forbes, Appellant Pro Se. Unpublished opinions are not binding precedent in this circuit. USCA4 Appeal: 25-6325 Doc: 9 Filed: 09/23/2025 Pg: 2 of 2 PER CURIAM: Dennis A. Forbes, a federal inmate, filed a 28 U.S.C. § 2241 petition and related motions, challenging the execution of his sentence and the validity of a removal order and immigration detainer. He appeals the district court’s order accepting the recommendation of the magistrate judge and denying relief. On appeal, we confine our review to the issues raised in the informal brief. See 4th Cir. R. 34(b). Because Forbes’s informal brief does not challenge the district court’s determination that he failed to exhaust administrative remedies before filing his § 2241 petition and that the court lacked jurisdiction to review the immigration detainer, he has forfeited appellate review of those issues. See 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 find no reversible error in the district court’s denial of Forbes’s remaining claims. Forbes’s claim that he is entitled to earn Federal Earned Time Credits under the First Step Act of 2018 is moot because Forbes has been released from the Bureau of Prisons and is being held in an immigration detention facility in Pennsylvania, and any challenge to his immigration detention must be filed in the district of confinement. Accordingly, we affirm the district court’s order. We dispense with oral argument because the facts and legal contentions are adequately presented in the materials before this court and argument would not aid the decisional process. AFFIRMED 2