Summary
The United States District Court for the District of South Carolina adopts a magistrate judge’s Report and Recommendation and dismisses Steven Eddington’s claims against the South Carolina Department of Corrections with prejudice. The court notes that Eddington filed no objections and provides notice of his right to appeal within thirty days.
Topics
Practice areas
Questions Presented
- Whether the district court should review the unobjected-to Report and Recommendation for clear error rather than de novo.
- Whether the Report and Recommendation dismissing Eddington's claims against the South Carolina Department of Corrections with prejudice should be adopted.
Holdings
- When a party fails to file timely objections to a magistrate judge's Report and Recommendation, the district court need not conduct de novo review and need only satisfy itself that there is no clear error on the face of the record before accepting the recommendation.
- The court adopted the magistrate judge's Report and Recommendation and dismissed with prejudice Eddington's claims against the South Carolina Department of Corrections.
- A party's failure to file timely objections to a magistrate judge's Report and Recommendation waives appellate review.
Key quotations
“[I]n the absence of a timely filed objection, a district court need not conduct a de novo review, but instead must ‘only satisfy itself that there is no clear error on the face of the record in order to accept the recommendation.’” (unpaginated)
Factual background
Steven Eddington, a state prisoner, filed a pro se civil-rights action under 42 U.S.C. § 1983 against the South Carolina Department of Corrections and multiple prison personnel. The magistrate judge recommended dismissing the claims against the Department with prejudice and separately authorized service on the individual defendants. Eddington did not object to the Report and Recommendation.
Procedural history
Eddington, a state prisoner proceeding pro se, filed a 42 U.S.C. § 1983 action against the South Carolina Department of Corrections and various individual prison personnel. The magistrate judge issued a Report and Recommendation on March 19, 2026, recommending dismissal with prejudice as to the Department, while separately authorizing summonses for the individual defendants. The district court adopted the Report and Recommendation and dismissed the claims against the Department with prejudice; the claims against the individual defendants were not dismissed by this order.