Facts of the Case

Provided by Oyez

While serving a 15-year federal prison sentence in 2017, Donte Parrish sued the United States for $5 million, claiming prison officials unlawfully held him in administrative segregation for three years. After the district court dismissed his case in March 2020, Parrish did not receive notice of the dismissal until June 2020 due to his transfer to state custody. He promptly filed a notice of appeal, which the appeals court treated as a request to reopen his appeal time. The district court granted this request in January 2021, giving him 14 days to file a new appeal, but Parrish missed this deadline and instead sent a supplemental brief to the appeals court a few days late. The U.S. Court of Appeals for the Fourth Circuit dismissed his appeal for lack of jurisdiction.

Questions

  1. Must a party who files a notice of appeal during the period between when their original appeal deadline expired and when the court reopens their time to appeal file a second notice after the reopening is granted?

Conclusions

  1. The Federal Rules of Appellate Procedure require a timely-filed notice of appeal, and a notice filed after the original deadline but before a court grants reopening relates forward to the date reopening is granted, making a second notice unnecessary. Justice Sonia Sotomayor authored the 6-3 majority opinion of the Court.

    When civil litigants miss appeal deadlines, federal law provides two exceptions: courts may extend the deadline for excusable neglect or good cause, or reopen the appeal period when a party entitled to notice does not receive it within 21 days of the judgment. The reopening provision creates a new 14-day appeal window starting from the court's reopening order. While a notice filed after this 14-day period cannot confer jurisdiction, a notice filed before reopening is granted is merely premature rather than late. Congress legislated against established common-law principles that premature but adequate notices of appeal relate forward to the entry of the document making an appeal possible. For over a century, courts have applied this principle to avoid dismissing appeals on technicalities when no doubt exists about who is appealing, from what judgment, and to which court.

    The statute’s silence on pre-reopening notices means Congress expected the longstanding relation-forward rule to continue applying. Requiring a second notice after reopening would serve no purpose beyond “empty paper shuffling” when the original notice already provided clear notice of the intent to appeal. The Federal Rules of Appellate Procedure support this interpretation, as Rules 4(a)(2) and 4(a)(4) codify the principle that premature notices should relate forward when they do not prejudice opposing parties. The 1993 amendments specifically eliminated restrictions on relation-forward to avoid creating traps for litigants, especially pro se litigants who often fail to file second notices. Rule 4(a)(6)’s silence on relation-forward does not create a negative implication prohibiting it, particularly given the Rules’ emphasis on securing just determinations and disregarding errors that do not affect substantial rights.

    Justice Ketanji Brown Jackson authored a concurring opinion, joined by Justice Clarence Thomas, arguing the same result could be reached without relation-forward principles by treating the filing as a motion with an attached proposed notice of appeal.

    Justice Neil Gorsuch filed a dissenting opinion, arguing the case should have been dismissed as improvidently granted because the Rules Committee is already studying this issue.