Hamer v. Neighborhood Hous. Servs. of Chi.
Headline: Court rules that a court-made deadline for filing an appeal does not automatically block courts from hearing late appeals, vacating a dismissal and limiting when lower courts can toss appeals.
Holding: The Court held that a deadline found only in a court rule for extending appeal time is not jurisdictional, so the appeals court wrongly dismissed the woman’s appeal.
- Stops courts from automatically dismissing appeals for missing court-made extension limits.
- Allows late appellants more chance to proceed when lower courts grant longer extensions.
- Leaves waiver and forfeiture questions for lower courts to resolve.
Summary
Background
A woman who sued two former employers for job discrimination lost in federal district court after the judge granted summary judgment. Her lawyers asked to withdraw and asked the district court for more time to file a notice of appeal; the court extended the deadline from mid-October to December 14, 2015. The defendants did not object in the district court, and the woman filed her appeal on December 11, 2015. The federal appeals court later questioned timeliness and, after the defendants argued the extension exceeded a 30-day limit in a court rule, dismissed the appeal for lack of jurisdiction.
Reasoning
The Supreme Court explained that only a law passed by Congress can set a time limit that automatically takes away a court’s power to hear an appeal. A time limit found only in a court-made rule is a mandatory procedural rule, not a rule that removes a court’s authority. Because the 30-day limit the appeals court relied on appears in an appellate rule—not in the statute Congress wrote—the rule is not “jurisdictional.” The Court therefore held the appeals court erred in treating the rule-based limit as an absolute bar and vacated the dismissal.
Real world impact
The decision means lower courts should not automatically toss out appeals based solely on court-made time limits; such rules can be forfeited if not properly raised. The Supreme Court sent the case back for further proceedings so the appeals court can resolve whether the defendants’ failure to object earlier or other equitable factors affect the outcome.
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