Background
The U.S. Court of Federal Claims entered judgment on March 25, 2026, dismissing Charles-Clifton Beal’s complaint for lack of subject-matter jurisdiction. Beal, who was incarcerated, sought Federal Circuit review of that judgment.
Beal’s notice of appeal was dated May 22, 2026. His prison’s legal-mail system marked it received, and it was postmarked, on May 27, 2026; the Court of Federal Claims received it on June 3, 2026. After the Federal Circuit ordered the parties to show cause concerning timeliness, Beal requested various forms of relief but did not address whether his appeal was timely.
The Court’s Holding
In a nonprecedential per curiam order, the Federal Circuit dismissed the appeal as untimely. Under 28 U.S.C. §§ 2107(b) and 2522, a notice of appeal ordinarily must be received by the Court of Federal Claims within 60 days after entry of judgment. The court explained that this statutory deadline is mandatory and jurisdictional and therefore cannot be excused.
The court declined to treat the notice as filed on May 22 because Beal did not provide the declaration required by Federal Rule of Appellate Procedure 4(c)(1), and the record did not otherwise establish timely delivery to prison authorities. The earliest supported filing date was May 27—the postmark and prison legal-mail receipt date—but that date was still outside the 60-day period. The court granted the government leave to file its response out of time, denied Beal’s other requested relief, and ordered each side to bear its own costs.
Key Takeaways
- The statutory deadline for appealing a Court of Federal Claims judgment is mandatory and jurisdictional.
- An incarcerated litigant seeking the benefit of the prison mailbox rule must satisfy Rule 4(c)(1) or provide other evidence showing timely deposit with prison authorities.
- A date written on a notice of appeal does not, without the required declaration or supporting evidence, establish the filing date.
Why It Matters
The order underscores that appellate deadlines can foreclose review regardless of the merits of the underlying case. For incarcerated litigants, compliance with the prison mailbox rule’s declaration and evidentiary requirements is critical because the date of deposit with prison officials may determine whether appellate jurisdiction exists.