Bowles v. Russel

Brief Fact Summary.

Petitioner filed an application for habeas corpus following his murder conviction.

Synopsis of Rule of Law.

The statutory period established in Rule 4(a) is jurisdictional and cannot be excused through waiver by a district court.

Facts.

Keith Bowles (Petitioner) was convicted of murder and sentenced to fifteen years imprisonment. Petitioner appealed, and then filed a federal habeas corpus application.

Issue.

Is an appeal filed after the statutory period of Rule 4(a) but within the extended time allotted by the district court untimely?

Held.

Yes, the appeal is untimely if it is filed after the statutory period in Rule 4(a). The decision of the Court of Appeals is affirmed.

Dissent.

Justice Souter

Justice Souter argued that Petitioner should not be punished for relying on the District Court’s grant of a seventeen day extension. Additionally, Justice Souter argued that the statutory period should not be considered jurisdictional without Congress saying so.

Discussion.

The Court determined that the statutory period established in Rule 4(a) is jurisdictional, and thus the Court of Appeals lacked jurisdiction over any appeal filed after the fourteen day extension. Furthermore, the Court dismissed Petitioner’s argument that his untimely filing could be excused by the unique circumstances doctrine because the doctrine was outdated and jurisdictional requirements could not be excused through equitable exceptions.