Cheddie Lamar Griffin, a prisoner proceeding pro se, appealed from a district court order denying his motion to amend an original 28 U.S.C. § 2255 motion. The Eleventh Circuit had previously remanded the case to the district court to consider a construed motion for relief under Federal Rule of Appellate Procedure 4(a)(6), which allows courts to reopen the appeal period under certain circumstances. On remand, the district court denied this motion, leading Griffin to file a notice of appeal. The core dispute centers on whether the appellate court has the authority to hear the case given the timing of that filing.
The court explained that habeas corpus proceedings under § 2255 are governed by the Federal Rules of Civil Procedure, making the timely filing of a notice of appeal a jurisdictional requirement. For civil cases where the United States is a party, the notice must be filed within 60 days after the entry of the challenged ruling. Griffin was required to file by March 4, 2025. However, under the prison mailbox rule, his notice was not deemed filed until March 10, 2025, the date he delivered it to prison authorities. Because the filing date missed the statutory deadline and the district court properly denied his motion to reopen the appeal period, the Eleventh Circuit lacked jurisdiction to review the merits of the appeal.
The appeal is dismissed, meaning the district court's denial of Griffin's § 2255 motion stands. All pending motions before the appellate court are denied as moot. The decision reinforces that strict adherence to the 60-day filing deadline for habeas appeals involving the United States is mandatory, and the prison mailbox rule does not extend the deadline if the mailed notice still arrives after the statutory period expires.