Collier v. United States

Background

A man convicted under the federal Mann Act lost at trial and had a formal judgment entered the same day. Nine days later his lawyer filed a motion for a new trial, but a different rule required such motions within five days, so the district court rejected it. A week after that denial the man filed a notice of appeal, and the Court of Appeals dismissed the appeal as too late.

Reasoning

The core question was whether a motion for a new trial filed within ten days of judgment can extend the time to file an appeal, even if that motion missed the five-day deadline for new-trial motions. The Court read the appeals rule literally and said the defendant’s filing fell within the ten-day appeal window after denial of the motion. The Government argued the motion should not count because it was doomed under the five-day rule, and the Court noted a recent rule amendment that would adopt that narrower approach going forward. Still, the Court concluded that letting the appeal proceed created little harm and that restricting the right to appeal on this basis was inappropriate.

Real world impact

The ruling lets this defendant’s appeal go forward and makes clear that, under the rules as written at the time, a timely-filed motion within ten days can extend the appeal clock. The opinion also records that the rules were amended prospectively to change this interaction and that the five-day filing window for new-trial motions was being adjusted.

Dissents or concurrances

Justice Black agreed with the result and pointed to reasoning adopted by a Fifth Circuit opinion, which the Court records as his basis for concurrence.