Houston v. Lack, Warden
487 U.S. 266 (1988)
Premium Feature
Subscribe to Lexplug to listen to the Case Podcast.
Rule of Law:
A notice of appeal filed by a pro se prisoner is considered timely if it is delivered to prison authorities for mailing on or before the filing deadline. This "prison mailbox rule" deems the notice "filed" at the moment the prisoner relinquishes control over it to prison officials.
Facts:
- Prentiss Houston, an inmate in a Tennessee prison, was acting pro se (representing himself).
- Houston drafted a notice of appeal to challenge the dismissal of his federal habeas corpus petition.
- On February 3, 1986, 27 days after the judgment, Houston deposited the notice with prison authorities to be mailed to the District Court.
- The date Houston deposited the notice was recorded in the prison's official mail log.
- Houston requested that the prison certify the mailing date and send the notice via air mail, but the prison refused because he lacked the funds to pay for these services.
- The notice of appeal was stamped "filed" by the Clerk of the District Court on February 7, 1986, 31 days after the judgment was entered, making it one day past the 30-day deadline.
Procedural Posture:
- Prentiss Houston filed a pro se petition for a writ of habeas corpus in the U.S. District Court for the Western District of Tennessee.
- The District Court dismissed the petition on January 7, 1986.
- Houston's notice of appeal was received and stamped 'filed' by the District Court Clerk on February 7, 1986, one day after the 30-day filing deadline had expired.
- The District Court issued a certificate of probable cause, allowing the appeal to proceed.
- On its own motion, the U.S. Court of Appeals for the Sixth Circuit ordered Houston to show cause why the appeal should not be dismissed as untimely.
- After appointing counsel for Houston on the timeliness issue, the Court of Appeals for the Sixth Circuit dismissed the appeal for want of jurisdiction.
- The U.S. Supreme Court granted certiorari to review the dismissal.
Premium Content
Subscribe to Lexplug to view the complete brief
You're viewing a preview with Rule of Law, Facts, and Procedural Posture
Issue:
Under Federal Rule of Appellate Procedure 4(a)(1), is a pro se prisoner's notice of appeal deemed 'filed' at the moment it is delivered to prison authorities for forwarding to the district court?
Opinions:
Majority - Justice Brennan
Yes. A pro se prisoner's notice of appeal is filed at the moment it is delivered to prison authorities for forwarding to the district court. Prisoners are in a unique situation because they cannot personally file documents with the court or monitor the mailing process. Their control over the notice ceases entirely once they hand it over to prison officials, who they cannot supervise and who may have incentives to delay. This bright-line rule, known as the prison mailbox rule, avoids difficult factual inquiries into mail delays or clerical errors and relies on the straightforward evidence of prison mail logs. This interpretation is consistent with the analysis in Fallen v. United States, which treated the jailer as effectively the clerk of the court for filing purposes in such unique circumstances.
Dissenting - Justice Scalia
No. A notice of appeal is 'filed with the clerk' only when the clerk actually receives it, regardless of the appellant's status. The majority's decision is an act of judicial enactment, not textual construction. The plain text of the Federal Rules of Appellate Procedure requires filing with the clerk, which has historically meant receipt by the clerk. Creating a special exception for prisoners undermines the certainty of a mandatory and jurisdictional deadline. If the rule works a hardship on prisoners, the proper remedy is to amend the rule through the established process involving Congressional oversight, not for the Court to create ad hoc exceptions for sympathetic cases.
Analysis:
This landmark decision establishes the federal 'prison mailbox rule,' creating a significant procedural protection for pro se incarcerated litigants. It acknowledges the unique logistical helplessness of prisoners and shifts the focus of the timeliness inquiry from the court's receipt to the prisoner's act of relinquishing control. This ruling resolved a circuit split and provided a clear, administrable standard that avoids complex, case-by-case analyses of mail delays. The principle has since been formally codified in the Federal Rules of Appellate Procedure (Rule 4(c)), cementing its importance in ensuring access to the courts for the incarcerated.
Unlock the full brief for Houston v. Lack, Warden