Your search Notice: Fourth Circuit Local Rule 36(c) States That Citation of Unpublished Dispositions is Disfavored Except for Establishing Res Judicata, Estoppel, or the Law of the Case and Requires Service of Copies of Cited Unpublished Dispositions of the Fourth Circuit.w.s. Frey Company, Incorporated, Petitioner, v. Secretary of United States Department of Labor; Mine Safetyand Health Administration; Federal Mine Safetyand Health Review Commission, Respondents did not match any document.