Reynolds v. United States
- Laura Swain
- 1:25-cv-02818
- U.S. District Court · Southern District of New York
- 2
In Reynolds v. United States, Judge Swain denied Reynolds’s appeal-extension motion as unnecessary because his notice was timely.
Michael C. Reynolds, who sought extra time to appeal, was denied an extension because the court found his notice of appeal timely. The court also denied permission to appeal this order without paying filing costs.
What happened
In Reynolds v. United States, Michael C. Reynolds, who is incarcerated and represented himself, asked for more time to appeal an earlier dismissal. The court had entered judgment on April 15, 2025.
Because the United States and federal agencies were defendants, Reynolds had 60 days to file a notice of appeal. The court treated his filing as timely under the rule for papers submitted by incarcerated people.
Judge Laura Taylor Swain denied the extension motion as unnecessary and directed the Clerk to terminate it. She also ruled that any appeal from this order would not be taken in good faith and denied permission to appeal without paying filing costs.
The detailed version
- Reynolds v. United States · No. 1:25-cv-02818
- Laura Swain
- July 1, 2025
Background
Michael C. Reynolds, who is currently incarcerated in FCI Schuylkill, filed this action without a lawyer against the United States of America, the Department of Justice, the United States Probation Office, and the Federal Bureau of Prisons. The court had dismissed the action by an April 10, 2025 order, and the Clerk entered judgment on April 15, 2025.
On June 18, 2025, the court received Reynolds’s motion for an extension of time to file a notice of appeal and his notice of appeal.
Court’s analysis
Federal Rule of Appellate Procedure 4(a)(1)(B) gives a party 60 days to appeal when the United States or a federal agency is a party in a civil case. The court concluded that Reynolds’s filing was within that period. Applying the rule that, absent contrary evidence, an incarcerated person’s court filing is treated as submitted when the person signs it, the court treated Reynolds’s extension motion as filed on May 31, 2025.
Because the judgment was entered on April 15, 2025, the court determined that Reynolds’s notice of appeal was timely. The requested extension was therefore unnecessary.
Ruling
Judge Laura Taylor Swain denied Reynolds’s motion for an extension of time to file a notice of appeal as unnecessary and directed the Clerk of Court to terminate the motion on the docket. The court also certified under 28 U.S.C. § 1915(a)(3) that an appeal from this order would not be taken in good faith and denied permission to appeal without paying filing costs. This order addressed the appeal deadline and related filing-cost issue; the opinion does not explain why the earlier action was dismissed.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.