Parrish v. United States

Federal inmate Donte Parrish was placed in restrictive segregated confinement for 23 months based on suspected involvement in another inmate's death. After a hearing officer cleared him, Parrish filed suit in Federal District Court seeking damages. The District Court dismissed his case on March 23, 2020. Parrish, transferred to another facility, did not receive the dismissal order until three months later. He promptly filed a notice of appeal, which the Fourth Circuit construed as a motion to reopen the appeal time under 28 U.S.C. §2107(c). The District Court granted reopening for 14 days, but Parrish did not file a second notice of appeal. Although both parties agreed the original notice was sufficient, the Fourth Circuit held that failure to file a new notice deprived it of jurisdiction. The Supreme Court reversed.

The Supreme Court held that a litigant who files a notice of appeal after the original deadline but before the court grants reopening need not file a second notice after reopening. The original notice relates forward to the date reopening is granted. Justice Sotomayor delivered the majority opinion, joined by Chief Justice Roberts and Justices Alito, Kagan, Kavanaugh, and Barrett. Justice Jackson filed a concurring opinion joined by Justice Thomas. Justice Gorsuch dissented. The Fourth Circuit's decision was reversed and the case remanded.

Whether a litigant who files a notice of appeal after the original appeal deadline but before the court grants reopening under 28 U.S.C. §2107(c) must file a second, duplicative notice of appeal after reopening is granted.

The decision resolved a circuit split regarding appellate procedure. It clarified that a motion to reopen the appeal window can itself function as a premature but permissible notice of appeal, protecting pro se litigants from being ensnared by technical procedural requirements. The ruling promotes judicial efficiency by preventing "empty paper shuffling" and ensures that the notice of appeal's purpose—to provide clear notice of intent to appeal—is given primacy over rigid formalism.