Background
Yoandy Alonso Figueredo appealed a final criminal judgment entered on July ninth, two thousand and twenty-four. The government moved to dismiss the appeal as untimely, arguing that the notice of appeal was not filed within the required timeframe.
The court’s reasoning
The court determined that the notice of appeal, deemed filed on May first, two thousand and twenty-five, under the prison mailbox rule, was untimely to appeal from the July ninth, two thousand and twenty-four final criminal judgment. The court cited Federal Rule of Appellate Procedure four, subsection B, paragraph one, subsection A, subsection one, which requires a defendant’s notice of appeal to be filed within fourteen days after entry of the appealed judgment. The court noted that this time limit is a non-jurisdictional claims-processing rule that must be enforced if raised by the government. Citing United States versus Lopez, Manrique versus United States, and Nutraceutical Corporation versus Lambert, the court explained that this mandatory claim-processing rule is not subject to equitable tolling. Because the government raised the timeliness issue, the court applied the time limits of Rule four, subsection B and dismissed the appeal.
What it means going forward
This ruling reinforces that strict adherence to the fourteen-day deadline for filing criminal appeals is required, even when the prison mailbox rule applies, and that equitable tolling is unavailable for this mandatory claims-processing rule.