Andre Youngblood filed a lawsuit in the United States Court of Federal Claims, which entered a final judgment on August 14, 2025, dismissing his case for failure to pay the filing fee. Youngblood, who was incarcerated at the time, filed a notice of appeal on February 18, 2026, designating an earlier order dismissing his case for non-payment of fees. Under federal law, an appellant typically has 60 days to file a notice of appeal following a final decision from the Court of Federal Claims. The government moved to dismiss the appeal, arguing the filing was untimely, and Youngblood did not file a response.
The court reasoned that the timely filing of a notice of appeal from the Court of Federal Claims is a jurisdictional requirement that must be enforced. The court noted that Youngblood's notice of appeal was untimely as to the final judgment. While the court acknowledged that Youngblood appeared to be incarcerated, it emphasized that the prison mailbox rule under Federal Rule of Appellate Procedure 4(c) requires the appellant to submit a declaration or evidence establishing that they deposited their notice in the institution's mail system with first-class postage prepaid on or before the last day for filing. Because Youngblood failed to provide such evidence, the court could not find the filing was timely.
The appeal is dismissed without prejudice to a new filing if jurisdiction can be established within the statutory period. The dismissal means the Court of Federal Claims' judgment stands, and Youngblood must ensure any future appeal is filed within the 60-day window or provide sufficient evidence of timely deposit under the prison mailbox rule if he is incarcerated.
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