Hamer v. Neighborhood Housing Services of Chicago

Charmaine Hamer sued her former employer, Neighborhood Housing Services of Chicago, for employment discrimination. The U.S. District Court granted summary judgment in favor of the employer, but the decision was not set out in a separate document as required by Federal Rule of Civil Procedure 58(a). Hamer filed a notice of appeal beyond the standard 30-day window but within the 180-day period that applies when a separate judgment is not entered. The U.S. Court of Appeals for the Seventh Circuit dismissed the appeal for lack of jurisdiction, treating the 30-day statutory deadline as a rigid jurisdictional bar. The Supreme Court granted certiorari to resolve a circuit split over whether the rule extending the appeal deadline is jurisdictional or a claim-processing rule.

In a unanimous opinion authored by Justice Ruth Bader Ginsburg, the Supreme Court held that the 30-day appeal deadline is a nonjurisdictional claim-processing rule, not a jurisdictional limit. Because the district court failed to comply with the separate-document requirement of Rule 58(a), the judgment was not considered entered, and the 180-day appeal period applied. The Court reversed the Seventh Circuit's dismissal and remanded the case for further proceedings.

Whether the 30-day deadline for filing a notice of appeal under 28 U.S.C. § 2107 is a jurisdictional requirement, and whether a district court's failure to issue a separate judgment under Rule 58(a) renders the appeal untimely and deprives the court of appeals of jurisdiction.

The ruling drew a critical distinction between jurisdictional rules and mandatory claim-processing rules, reinforcing that procedural protections like the separate-document requirement are enforceable. It ensured that litigants are not unfairly penalized for court administrative errors, promoting fairness and predictability in appellate practice across the federal system.