4th Cir.

Tyler v. South Carolina

June 24, 2026 ·26-6061 ·Per Curiam · By Maria Santos

The United States Court of Appeals for the Fourth Circuit dismissed an appeal filed by Larry James Tyler. The court ruled that the notice of appeal was not filed within the required thirty-day window.

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Background

Larry James Tyler, proceeding pro se, sought to appeal a district court order denying his motion for a preliminary injunction and temporary restraining order. The district court had entered its order on October eighth, 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, parties have thirty days to file a notice of appeal after a final judgment. The appeal period expired on November seventh, two thousand and twenty-five, but Tyler filed the notice on December twenty-eighth, two thousand and twenty-five. The court cited Bowles versus Russell to state that timely filing is a jurisdictional requirement.

"[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 appeal is dismissed, leaving the district court’s denial of the preliminary injunction in place.