4th Cir.

Michael Ray Sigmon v. William Frederick Hughes, Sr.

March 26, 2026 ·25-1577 ·Per Curiam · By Maria Santos

The United States Court of Appeals for the Fourth Circuit dismissed an appeal because the notice of appeal was not filed within the required timeframe. The court held that timely filing is a jurisdictional requirement that cannot be waived.

Background

Michael Ray Sigmon sought to appeal a district court order that accepted a magistrate judge’s recommendation and dismissed his civil complaint. The district court entered its order and judgment on April eleventh, two thousand and twenty-five.

The court’s reasoning

The court determined that the appeal period expired on Monday, May twelfth, two thousand and twenty-five. Sigmon filed the notice of appeal on May eighteenth, two thousand and twenty-five. Because Sigmon failed to file a timely notice of appeal or to obtain an extension or reopening of the appeal period, the court dismissed the appeal for lack of 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

Litigants must strictly adhere to the thirty-day deadline for filing notices of appeal in civil cases to preserve appellate jurisdiction.