Parrish v. United States
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Overview
Overview
A federal prisoner filed a notice of appeal after his original deadline had passed but before the district court formally reopened the appeal window, and then faced the question of whether he needed to file a second notice once reopening was actually granted. The Supreme Court said no, 8-1, in June 2025: the original notice relates forward to the date reopening is granted, so a second filing is not required.
The Conclusion
Conclusion
The Supreme Court held 8-1 that a prisoner's notice of appeal filed before formal reopening relates forward to the reopening date. No second notice is required. The decision eased procedural burdens in appellate review for incarcerated litigants.
Summary
A federal prisoner filed a notice of appeal after his original deadline had passed but before the district court formally reopened the appeal window, and then faced the question of whether he needed to file a second notice once reopening was actually granted. The Supreme Court said no, 8-1, in June 2025: the original notice relates forward to the date reopening is granted, so a second filing is not required.
Conclusion
The Supreme Court held 8-1 that a prisoner's notice of appeal filed before formal reopening relates forward to the reopening date. No second notice is required. The decision eased procedural burdens in appellate review for incarcerated litigants.
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