The U.S. Court of Appeals for the Fourth Circuit vacated and remanded a federal district court's decision in a civil rights case involving allegations of discrimination against a minority-owned business in Prince George's County, Maryland.
Randy Richardson filed the lawsuit against Prince George's County under 42 U.S.C. § 1983, claiming the county's Department of Permitting, Inspections, and Enforcement violated his Fourteenth Amendment equal protection rights. Richardson alleged the department treated his minority-owned small business differently from non-minority-owned, large commercial businesses through harassment, improper fines, and preventing him from opening his business.
The case was originally heard in the U.S. District Court for the District of Maryland at Greenbelt, where District Judge George Jarrod Hazel granted the county's motion for judgment on the pleadings under Federal Rule of Civil Procedure 12(c). This procedural ruling effectively dismissed Richardson's case at an early stage, finding his complaint failed to state a valid legal claim.
Richardson appealed the dismissal to the Fourth Circuit, which heard oral arguments on Dec. 10, 2025. The three-judge panel included Circuit Judges J. Harvie Wilkinson III and James Andrew Wynn Jr., along with Senior Circuit Judge Barbara Milano Keenan, who authored the court's opinion.
The Fourth Circuit's Feb. 3, 2026 decision reversed the district court's judgment and sent the case back for further proceedings. The appellate court issued an unpublished opinion, meaning it does not create binding precedent for future cases in the circuit. All three judges on the panel concurred in the decision to vacate and remand.
The defendants in the case include Prince George's County itself, along with named officials Angela Alsobrooks and Melinda Bolling. Alsobrooks previously served as Prince George's County Executive and is currently Maryland's U.S. Senator, while Bolling's specific role in the case was not detailed in the available court documents.
Richardson was represented by attorney Jordan David Howlette of Justly Prudent in Washington, D.C. The county defendants were represented by Roger Cole Thomas of the Law Offices of Roger C. Thomas in Greenbelt, Maryland, with additional counsel including County Attorney Rhonda L. Weaver and Shelley L. Johnson from the Prince George's County Office of Law in Largo, Maryland.
The case centers on Richardson's allegations that the county's permitting department engaged in discriminatory enforcement practices. Under Section 1983, individuals can sue state and local government officials for violating their constitutional rights under color of state law. Equal protection claims under the Fourteenth Amendment require plaintiffs to show they were treated differently from similarly situated individuals without adequate justification.
For minority business discrimination cases, courts typically apply heightened scrutiny when evaluating whether differential treatment was based on race or ethnicity. Richardson's complaint appears to have alleged that large, non-minority businesses received more favorable treatment from the permitting department than his small, minority-owned enterprise.
The district court's grant of judgment on the pleadings under Rule 12(c) suggests the court found Richardson's complaint legally insufficient even accepting all factual allegations as true. This standard requires courts to determine whether the pleading fails to state a claim upon which relief can be granted, similar to a motion to dismiss under Rule 12(b)(6).
The Fourth Circuit's decision to vacate and remand indicates the appellate court disagreed with the district court's analysis, finding Richardson's complaint contained sufficient allegations to proceed past the pleading stage. However, the specific reasoning behind the Fourth Circuit's decision was not available in the court filing excerpts.
The remand means the case will return to District Judge Hazel's court for further proceedings consistent with the Fourth Circuit's opinion. This could include allowing Richardson to amend his complaint, proceeding to discovery where both sides gather evidence, or other case development depending on the appellate court's specific instructions.
Civil rights litigation against local governments often involves complex questions about municipal liability, individual official immunity, and the scope of constitutional protections for business owners. The outcome of this case could affect how Prince George's County's permitting department handles enforcement actions, particularly regarding minority-owned businesses.
The case highlights ongoing concerns about equal treatment in local government services and the role of federal courts in protecting civil rights at the municipal level. Prince George's County, located in Maryland's Washington D.C. suburbs, has faced various civil rights challenges over the years involving its governmental operations.
With the case now remanded, both sides will likely prepare for the next phase of litigation in district court. The ultimate resolution will depend on further factual development and legal arguments about whether Richardson can prove his discrimination claims under applicable constitutional and statutory standards.