## Facts

- Keith Bowles, an Ohio prisoner convicted of murder, sought federal habeas relief under 28 U.S.C. § 2254; the district court denied the petition.
- In civil cases, 28 U.S.C. § 2107(a) and Federal Rule of Appellate Procedure 4(a)(1)(A) generally require a notice of appeal within 30 days of judgment.
- Bowles did not file a timely notice of appeal, citing lack of timely notice of the district court’s judgment.
- Bowles moved to reopen the appeal period under Federal Rule of Appellate Procedure 4(a)(6) and 28 U.S.C. § 2107(c), which allow reopening under specified conditions for a maximum 14-day filing period.
- The district court granted reopening but mistakenly allowed 17 days to file.
- Bowles filed his notice of appeal within the 17 days authorized by the district court’s order, but after the 14-day maximum authorized by § 2107(c) and Rule 4(a)(6).

## Issues

1. Whether a court of appeals has jurisdiction over a civil appeal filed after the statutory deadline in 28 U.S.C. § 2107(c) but within a longer period stated in a district court’s erroneous reopening order.
2. Whether equitable relief (including the “unique circumstances” doctrine) can excuse noncompliance with a statutory notice-of-appeal deadline.

## Decision

- The Supreme Court held, 5–4, that Bowles’s notice of appeal was untimely because it was filed outside the 14-day period authorized by § 2107(c) and Rule 4(a)(6).
- Because the statutory time limit is jurisdictional, the court of appeals lacked jurisdiction and was required to dismiss the appeal.
- The district court’s mistaken order could not create appellate jurisdiction beyond the statutory limit.
- The Court rejected equitable exceptions and disapproved prior “unique circumstances” decisions to the extent they allowed exceptions to jurisdictional rules.

## Legal Principles

- Statutory time limits for filing a notice of appeal in civil cases are mandatory and jurisdictional; failure to comply deprives the court of appeals of jurisdiction.
- When Congress sets the conditions and maximum period for extending or reopening the time to appeal, courts may not enlarge that period by order or equitable doctrine.
- Courts lack authority to create equitable exceptions to jurisdictional requirements; reliance on a court’s erroneous deadline does not confer jurisdiction.
- A distinction exists between deadlines imposed by statute (jurisdictional) and those imposed solely by court rules (generally non-jurisdictional claim-processing rules).

## Conclusion

The Court ruled that an appeal filed outside the statutory reopening period in § 2107(c) must be dismissed for lack of jurisdiction, even if the appellant filed within an erroneously extended deadline set by the district court and reasonably relied on that order.


Bowles v. Russell, 551 U.S. 205 (2007)