Your search Notice: Fourth Circuit Local Rule 36(c) States That Citation of Unpublished Dispositions is Disfavored Except for Establishing Res Judicata, Estoppel, or the Law of the Case and Requires Service of Copies of Cited Unpublished Dispositions of the Fourth Circuit.frances E. Kirk, Widow of Lat Kirk, Petitioner, v. Director, Office of Workers' Compensation Programs, Unitedstates Department of Labor; Island Creek Coalcompany; Thyssen Mining Constructioncompany, Respondents did not match any document.