4th Cir.

Angela Ivey Thomas v. Maryland; Gladys M. Weatherspoon; Thomas W. Hodge; John A. Ansell; Brock & Scott, PLLC

Angela Ivey Thomas v. Maryland; Gladys M. Weatherspoon; Thomas W. Hodge; John A. Ansell; Brock & Scott, PLLC

July 21, 2026 ·26-1121 ·Per Curiam · By Aisha Johnson

The United States Court of Appeals for the Fourth Circuit dismissed an appeal filed by Angela Ivey Thomas due to a failure to meet jurisdictional deadlines. The court held that the notice of appeal was not timely filed, rendering the appellate court without authority to hear the case.

Listen to this decision 0:00 / 1:07

Background

Angela Ivey Thomas sought to appeal a district court order striking her third motion to reopen and vacate a prior order remanding a foreclosure action to state court. The district court had entered its order on December seventeenth, two thousand and twenty-five.

The court’s reasoning

The court determined that the notice of appeal was not timely filed. Under Federal Rule of Appellate Procedure four point A one A, parties have thirty days after the entry of a final judgment to note an appeal. The appeal period expired on January sixteenth, two thousand and twenty-six. Thomas filed the notice of appeal on February second, two thousand and twenty-six. The court cited Bowles versus Russell, noting that timely filing is a jurisdictional requirement. Because Thomas failed to file a timely notice or obtain an extension, the court lacked jurisdiction.

[T]he timely filing of a notice of appeal in a civil case is a jurisdictional requirement.

Bowles v. Russell, 551 U.S. 205, 214 (2007)

What it means going forward

The dismissal prevents appellate review of the district court’s procedural rulings regarding the foreclosure action and the motion to reopen.