Background
Sheila Knox, proceeding pro se, appealed from a judgment in her civil action against Consumer Portfolio Services. The U.S. District Court for the District of Maryland had granted summary judgment to Consumer Portfolio Services on April 22, 2026.
Knox also sought to challenge an October 17, 2025, order that had granted Consumer Portfolio Services’ motion to dismiss in part. Her notice of appeal, however, was filed outside the applicable 30-day appeal period, and she had not obtained an extension or reopening of that period.
The Court’s Holding
In an unpublished per curiam opinion, the Fourth Circuit affirmed the April 22, 2026, summary-judgment order. After reviewing the record, the panel found no reversible error. It decided the appeal without oral argument because the submitted materials adequately presented the facts and legal issues.
The court lacked jurisdiction to review the October 17, 2025, partial-dismissal order because Knox did not file a timely notice of appeal from that order. Citing the jurisdictional nature of the civil appeal deadline, the panel concluded that the untimely challenge could not proceed. The court also granted Consumer Portfolio Services’ motion for an extension of time to file its informal response brief.
Key Takeaways
- The Fourth Circuit affirmed summary judgment for Consumer Portfolio Services after finding no reversible error.
- The court lacked jurisdiction over Knox’s challenge to the earlier partial-dismissal order because her notice of appeal was untimely.
- A civil appellant who misses the 30-day appeal deadline must obtain an authorized extension or reopening to preserve appellate review.
Why It Matters
The decision underscores that a timely notice of appeal is a jurisdictional prerequisite in a civil case. An appeal from a later judgment does not permit review of an earlier order when the applicable appeal deadline has expired without an extension or reopening.
The opinion is unpublished and therefore is not binding precedent in the Fourth Circuit, but it illustrates the potentially dispositive effect of appellate filing deadlines.