Appellate Practice — Failure to Develop Argument in Brief, Including a Single Conclusory Sentence, Forfeits Appellate Review

Schnader Harrison Segal & Lewis LLP, 2014 U.S. App. LEXIS 11647 (4th Cir. June 20, 2014):

On appeal, Hershey also challenges the district  court's order granting Schnader's motion for Rule 11 sanctions.  "We review the decision to award sanctions for abuse of discretion." Newport News Holdings Corp. v. Virtual City Vision, Inc., 650 F.3d 423, 443 (4th Cir. 2011) (citation omitted). However, Hershey has failed in his appellate brief to develop an argument challenging the court's order. We therefore conclude that Hershey has forfeited appellate review of that order. See Eriline Co. S.A. v. Johnson , 440 F.3d 648, 653 n.7 (4th Cir. 2006) (finding conclusory single sentence in brief "insufficient to raise on appeal any merits-based challenge to the district court's ruling").

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