Williams v. Lorman, 24-1866-cv

Sean L. Williams, proceeding pro se, filed a lawsuit under 42 U.S.C. § 1983 against several Vermont officials, challenging the actions of the Office of Child Support and associated personnel.
The United States District Court for the District of Vermont dismissed Williams's suit pursuant to Federal Rule of Civil Procedure 4(m) for failing to properly serve any defendant.
Williams appealed the dismissal to the United States Court of Appeals for the Second Circuit.
On appeal, Williams failed to address the District Court’s stated reason for dismissing his action in his two-page appellate brief.
The Second Circuit considered the appeal without an appearance by defendants and issued a summary order affirming the District Court’s judgment.
The Court noted that even pro se litigants must explain how the lower court erred to preserve issues on appeal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Dismissal under Rule 4(m) for failure to serve	Williams did not set forth any identifiable argument	No appearance	Dismissal affirmed; failure to argue constitutes abandonment
Standard for pro se appellate briefs	Implicit request for liberal construction	N/A	Still must present clear arguments

Meilleur v. Strong, 682 F.3d 56 (2d Cir. 2012) (appellate court reviews Rule 4(m) dismissals for abuse of discretion)
Publicola v. Lomenzo, 54 F.4th 108 (2d Cir. 2022) (courts liberally construe pro se pleadings)
Terry v. Inc. Vill. Of Patchogue, 826 F.3d 631 (2d Cir. 2016) (pro se litigants must articulate identifiable arguments)
LoSacco v. City of Middletown, 71 F.3d 88 (2d Cir. 1995) (courts need not manufacture arguments for pro se parties)