United States v. King

Summary

In this unpublished Tenth Circuit decision, the court dismissed as untimely Eric King's appeal of a district court order denying his motion to amend his pretrial detention order. King filed his notice of appeal more than fourteen days after the detention order, missing the deadline under Federal Rule of Appellate Procedure 4(b)(1)(A)(i). Although Rule 4(b)(1)(A) is a non-jurisdictional claim-processing rule, the government properly invoked it, requiring dismissal of the untimely appeal. The case addresses the inflexibility of the 14-day appeal period for detention orders and the distinction between jurisdictional and claim-processing rules.

Holdings

1. The appeal of the April 2020 detention order is untimely because it was not filed within fourteen days as required by Fed. R. App. P. 4(b)(1)(A)(i).

Questions Presented

1. Whether the appeal of the April 2020 detention order was timely filed under Federal Rule of Appellate Procedure 4(b)(1)(A)(i).

Disposition

dismissed