Coy v. United States

Background

Bernard Paul Coy, representing himself, was convicted under the federal bank robbery statute and later sought to have his sentence vacated. After the district court denied that motion, Coy filed a notice of appeal and asked to proceed without paying court fees; the district court allowed his request. He then asked the Circuit Court of Appeals for leave to appeal without paying fees, but that court denied his petition even though the district court had already permitted the appeal.

Reasoning

The Court addressed whether the appeals court should have honored the district court’s grant to proceed without paying fees. Because the district court had allowed the appeal, the appeal was already properly before the appeals court and the appeals court should have permitted the appellant to proceed without fees. The Government acknowledged its mistake. The Supreme Court granted permission to file the petition here, granted review, vacated the appeals-court order, and sent the case back so the appeals court can make the appropriate disposition of the appeal.

Real world impact

The ruling resolves a procedural dispute: lower appellate courts must respect a district court’s order allowing an appeal without paying fees. The decision does not decide the underlying guilt or sentence; it simply requires the appeals court to address the appeal on its merits or otherwise dispose of it. The case was decided quickly and unanimously by a per curiam opinion with the Government confessing error.