Background
Angela Ivey Thomas sought to appeal an order from the U.S. District Court for the District of Maryland. The district court had struck her third motion to reopen the case and vacate an earlier order remanding the foreclosure action against her to state court.
The district court entered the challenged order on December 17, 2025. The 30-day period for filing a notice of appeal expired on January 16, 2026, but Thomas did not file her notice until February 2, 2026.
The Court’s Holding
The Fourth Circuit dismissed the appeal for lack of jurisdiction. Under Federal Rule of Appellate Procedure 4(a)(1)(A), a party in a civil case generally must file a notice of appeal within 30 days after entry of the final judgment or order, and timely filing is a jurisdictional requirement.
Because Thomas filed after the deadline and did not obtain an extension under Rule 4(a)(5) or reopening of the appeal period under Rule 4(a)(6), the court concluded that it lacked jurisdiction to hear the appeal. The panel dispensed with oral argument.
Key Takeaways
- A notice of appeal in a civil case generally must be filed within 30 days after entry of the challenged final judgment or order.
- The timely filing requirement is jurisdictional, so an appellate court cannot reach the merits when the deadline is missed.
- A late appellant must have obtained an extension or reopening of the appeal period under the applicable appellate rules.
Why It Matters
The decision underscores that appellate filing deadlines can determine the outcome before a court considers any substantive challenge to the underlying order. Repeated efforts to reopen a district court matter do not excuse an untimely notice of appeal from the order actually being challenged.