Ramsey Randall filed a complaint in the United States Court of Federal Claims, but the trial court dismissed his case on June 3, 2025, because he failed to pay the filing fee or submit a completed application to proceed in forma pauperis. Randall subsequently filed a motion for reconsideration, which the trial court rejected on July 2, 2025. Randall then filed a notice of appeal dated September 11, 2025, claiming he placed it in the prison mailbox on September 10, 2025. However, the trial court did not receive the notice until September 25, 2025. The United States moved to dismiss the appeal as untimely, and Randall did not respond to the court's order directing the parties to show cause.
The Federal Circuit applied a strict statutory standard to determine the timeliness of the appeal. Under 28 U.S.C. §§ 2107(b) and 2522, and Federal Rule of Appellate Procedure 4(a)(4)(A), a notice of appeal in a case against the United States must be received by the Court of Federal Claims within 60 days of the entry of the judgment or order disposing of the last timely-filed post-judgment motion. The court emphasized that this deadline is mandatory and jurisdictional, citing Marandola v. United States and Henderson v. Shinseki. Because the notice was not received within the 60-day window, the court lacked jurisdiction to hear the appeal and could not excuse the delay. Additionally, while Randall appeared to be incarcerated, the court noted that he failed to provide any declaration or evidence satisfying Fed. R. App. P. 4(c) to prove he deposited the notice in the prison mail system with first-class postage prepaid on or before the deadline. Without this evidence, the prison mailbox rule could not be invoked to validate the late filing.
The appeal is terminated with no relief granted to the appellant. The dismissal is final, and each party must bear its own costs. The decision reinforces that jurisdictional deadlines in appeals against the United States are strictly enforced, and incarcerated appellants must provide specific evidence of timely mailing to benefit from the prison mailbox rule.
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