Parrish v. United States

Background

Donte Parrish, a federal inmate, was placed in restrictive segregated confinement and later cleared of wrongdoing by a hearing officer. He sued the United States for damages, and the District Court dismissed his case on March 23, 2020. Parrish was transferred from the federal prison and only received the dismissal order months later, after the ordinary 60-day appeal deadline had passed. He filed a late notice of appeal that the Fourth Circuit treated as a motion to reopen the appeal period; the District Court then granted a 14-day reopening, but Parrish did not file a second notice.

Reasoning

The Court considered whether a notice filed after the original deadline but before a court grants reopening must be filed again. Relying on long-standing practice and prior decisions, the Court held that a premature but adequate notice “relates forward” to the date the reopening order is entered. The Court explained that the statute governing reopening, 28 U.S.C. §2107(c), does not displace that background rule and that the Federal Rules of Appellate Procedure support treating the original notice as effective once reopening is granted. The Court reversed the Fourth Circuit, concluding the original notice sufficed.

Real world impact

The ruling reduces the risk that people—especially incarcerated or unrepresented litigants—will lose the right to appeal because of delivery delays or procedural confusion. It eliminates the need for a duplicative second filing after a reopening and sends the case back for further proceedings; it does not decide the underlying merits of Parrish’s damage claims.

Dissents or concurrances

Justice Jackson (joined by Justice Thomas) agreed on the outcome but offered a simpler docketing explanation. Justice Gorsuch dissented, arguing the Rules Committee should address this change and that the Court should not have decided the case now.