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Houston v. Lack, 487 U.S. 266 (1988)
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General SummaryThis case is from a collection containing the full text of over 16,000 Supreme Court cases from 1793 to the present. The body of Supreme Court decisions are, effectively, the final interpretation of the Constitution. Only an amendment to the Constitution can permanently overturn an interpretation and this has happened only four times in American history.
Houston v. Lack, 487 U.S. 266 (1988)
Houston v. Lack No. 87-5428 Argued April 27, 1988 Decided June 24, 1988 487 U.S. 266
CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR
THE SIXTH CIRCUIT
Syllabus
While incarcerated in a Tennessee prison, petitioner drafted a pro se notice of appeal from the Federal District Court’s judgment dismissing his pro se habeas corpus petition, and, 27 days after the judgment, deposited the notice with the prison authorities for mailing to the District Court. The date of deposit was recorded in the prison’s outgoing mail log. Because petitioner lacked the necessary funds, prison authorities refused his requests to certify the notice for proof that it had been deposited for mailing on the day in question, and to send the notice air mail. Although the record contains no evidence of when the prison authorities actually mailed the notice or when the District Court actually received it, the court stamped the notice "filed" 31 days after the habeas judgment -- that is, one day after the expiration of the 30-day filing period for taking an appeal under Federal Rule of Appellate Procedure 4(a)(1). For this reason, the Court of Appeals dismissed the appeal as jurisdictionally out of time.
Held: Under Rule 4(a)(1), pro se prisoners’ notices of appeal are "filed" at the moment of delivery to prison authorities for forwarding to the district court. Cf. Fallen v. United States, 378 U.S. 139 (Stewart, J., concurring). Unskilled in law, unaided by counsel, and unable to leave the prison, a pro se prisoner’s control over the processing of his notice necessarily ceases as soon as he hands it over to the only public officials to whom he has access -- the prison authorities -- and the only information he will likely have is the date he delivered the notice to those authorities and the date ultimately stamped upon it. The 30-day deadline for filing notices of appeal set forth in 28 U.S.C. § 2107, which applies to civil actions including habeas proceedings, does not preclude relief for petitioner, since that statute does not define when a notice has been "filed" nor in any way suggests that, in the unique circumstances of a pro se prisoner, it would be inappropriate to conclude that such filing occurs at the moment of delivery to prison officials. Such conclusion is not negated by the fact that Rules 3(a) and 4(a)(1) specify that the notice should be "filed with the clerk of the District Court," since the relevant question is one of timing, not destination, and neither Rule sets forth criteria for determining the moment at which the filing has occurred. The general rule that receipt by the court clerk constitutes filing, although appropriate for most civil appeals, should not apply in the pro se prisoner context. Nothing in either Rule 3(a) or Rule 4(a)(1) compels the conclusion that receipt by the clerk must be the moment of filing in all cases, and, in fact, a number of federal courts have recognized exceptions to the general principle. Moreover, the rationale for the general rule is that the appellant has no control over delays after the court clerk’s receipt of the notice -- a rationale that suggests that the moment of filing here should be the moment when the pro se prisoner necessarily loses control over his notice: the moment of delivery to prison authorities for forwarding. The bright-line rule recognizing receipt by prison authorities as the moment of filing will also decrease disputes and uncertainty as to when a filing actually occurred, since such authorities keep detailed logs for recording the date and time at which they receive papers for mailing, and can readily dispute a prisoner’s contrary assertions. Relying on the date of receipt, by contrast, would raise difficult questions as to whether the prison authorities, the Postal Service, or the court clerk is to blame for any delay. Pp. 269-276.
819 F.2d 289, reversed.
BRENNAN, J., delivered the opinion of the Court, in which WHITE, MARSHALL, BLACKMUN, and STEVENS, JJ., joined. SCALIA, J., filed a dissenting opinion, in which REHNQUIST, C.J., and O’CONNOR and KENNEDY, JJ., joined, post, p. 277.
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Chicago: U.S. Supreme Court, "Syllabus," Houston v. Lack, 487 U.S. 266 (1988) in 487 U.S. 266 487 U.S. 267–487 U.S. 268. Original Sources, accessed November 24, 2024, http://originalsources.com/Document.aspx?DocID=87C4DGD63N2476T.
MLA: U.S. Supreme Court. "Syllabus." Houston v. Lack, 487 U.S. 266 (1988), in 487 U.S. 266, pp. 487 U.S. 267–487 U.S. 268. Original Sources. 24 Nov. 2024. http://originalsources.com/Document.aspx?DocID=87C4DGD63N2476T.
Harvard: U.S. Supreme Court, 'Syllabus' in Houston v. Lack, 487 U.S. 266 (1988). cited in 1988, 487 U.S. 266, pp.487 U.S. 267–487 U.S. 268. Original Sources, retrieved 24 November 2024, from http://originalsources.com/Document.aspx?DocID=87C4DGD63N2476T.
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