Plain-English summary
Court limits when late notices of appeal can be fixed after a party missed notice of judgment
The Court held that when a party did not receive timely notice of a district-court judgment, a later-filed notice of appeal must still meet Rule 4(a)(6)'s requirements to reopen the appeal period. The Fourth Circuit judgment was reversed and the case remanded for further proceedings consistent with the Court's interpretation.
Why this matters
The decision clarifies when courts may treat late notices of appeal as timely when a party did not get notice of judgment. That affects defendants and litigants who miss the ordinary appeal deadline because they weren't notified, and it sets a clear procedural route courts must follow before accepting late appeals.
Who may feel it
- Criminal defendants and civil litigants who say they didn’t receive timely notice of a district-court judgment
- District courts tasked with reopening appeal periods under Rule 4(a)(6)
- Federal courts of appeals that decide timeliness of notices of appeal
- Appellate counsel who must file or seek relief quickly when clients claim they lacked notice
Key questions
- Does a notice of appeal filed after the ordinary appeal period but before a district court reopens that period under Rule 4(a)(6) count as timely?