Your search Notice: Fourth Circuit Local Rule 36(c) States That Citation of Unpublished Dispositions is Disfavored Except for Establishing Res Judicata, Estoppel, or the Law of the Case and Requires Service of Copies of Cited Unpublished Dispositions of the Fourth Circuit.henry Meseke Immanuel, Plaintiff-appellant, v. Secretary of the Treasury of the United States; Treasury Ofthe United States, Defendants-appellees, v. Internal Revenue Service, Party in Interest did not match any document.