4th Cir.

Thomas Lee Farmer v. United States of America

June 2, 2026 ·26-6348 ·Per Curiam · By Aisha Johnson

The United States Court of Appeals for the Fourth Circuit dismissed an appeal filed by a pro se prisoner challenging district court orders. The court held that the appealed orders were neither final nor appealable interlocutory or collateral orders.

Background

Thomas Lee Farmer, proceeding pro se, sought to appeal two district court orders. The first order, dated February second, twenty twenty-six, granted the defendants’ motion for summary judgment and dismissed Farmer’s amended complaint with prejudice. The second order, dated March fifth, twenty twenty-six, granted Farmer’s motion for relief under Rule sixty of the Federal Rules of Civil Procedure, reopening the case.

The court’s reasoning

The court explained that it may exercise jurisdiction only over final orders under Section twelve hundred and ninety-one of Title twenty-eight of the United States Code, and certain interlocutory or collateral orders under Section twelve hundred and ninety-two. The court found that the orders Farmer sought to appeal were neither final nor appealable. The footnote clarifies that the February order would have been final had the district court not granted the Rule sixty motion before Farmer filed his notice of appeal.

What it means going forward

The appeal is dismissed for lack of jurisdiction, leaving the district court’s summary judgment order in effect pending further proceedings or a new final order.