The U.S. Supreme Court on June 12 revived on an 8-1 vote a federal inmate’s stalled lawsuit over alleged mistreatment in prison after it was dismissed for missing a court filing deadline.

The new ruling is concerned with procedural rules—as opposed to the merits of the inmate’s lawsuit—and may make it easier for prisoners to pursue appeals.

Justice Sonia Sotomayor wrote the court’s majority opinion in Parrish v. United States. Justice Neil Gorsuch wrote a dissenting opinion.

The petitioner, Donte Parrish, sued the federal government in April 2017 in federal district court in West Virginia for compensation based on his claim that he was wrongfully placed in administrative segregation for three years after being accused of murdering a fellow inmate. Parrish denied involvement in the killing.

Parrish was a pro se litigant at trial, meaning he represented himself in court. Prisoners often do not have attorneys representing them in lawsuits. Parrish later hired an attorney during the appeals process.

When he filed the lawsuit, Parrish was incarcerated at a federal penitentiary in Inez, Kentucky, where he was serving a 180-month sentence for an offense that was not specified in court papers.

The murder took place in December 2009 during a riot at the prison where Parrish was then being held. The Federal Bureau of Prisons charged Parrish in the killing and placed him in administrative segregation “while the FBI spent nearly six years purportedly investigating the incident,” according to the petition.

Inmates are given administrative segregation status when they are deemed in need of protective custody, or “when they are under investigation for misconduct and/or criminal behavior, they need to be separated from other offenders for security reasons, or they are awaiting transfer/or in-transit (holdover) status,” according to the Bureau of Prisons website.

Parrish said in his petition that 20 months of his segregation consisted of spending time in a unit that was known as “the worst place in the federal prison system.”

Parrish said he was isolated in a small cell, was denied access to his property, lost law library privileges, was denied family visits, had difficulty contacting his lawyer, and was denied access to showers.

The murder charge was eventually dropped.

A federal district court dismissed his lawsuit on March 23, 2020, and sent notice of the dismissal to a federal prison in Illinois where he had previously been held.

Parrish said he did not receive the notice until after the 90-day appeal period had passed because he was in the process of being transferred from one correctional facility to another.

He asked the U.S. Court of Appeals for the Fourth Circuit to review the dismissal, and that court interpreted the request as a motion to reopen the appeal period. The circuit court returned the case to the district court.

The district court ruled that Parrish received the dismissal notice more than 21 days after it was sent, that he asked for the appeal period to be reopened within 14 days of receipt, and that neither side would be harmed by reopening the appeal period.

The district court ordered the reopening of the period for 14 days, after which the case was sent back to the Fourth Circuit. In that circuit court proceeding, both sides agreed that “Parrish’s original notice of appeal had become effective in light of the reopened appeal period,” the petition said.

A divided Fourth Circuit panel then ruled it had no authority to hear Parrish’s appeal because he had “not file[d] a timely notice of appeal.”

A majority on the panel found that Parrish was obligated to file a fresh notice of appeal within 14 days of the district court’s ruling to reopen, rejecting his argument “that when the district court reopened the time to appeal … it ‘validated’ his prior untimely notice of appeal.”

Parrish asked for a rehearing. The government agreed with him that the panel erred when it found it lacked authority to rehear the case but took no position on whether a rehearing should be granted. The panel, and then the full circuit court, voted to deny rehearing.

Justice Sotomayor wrote that when a federal district court reopens a case for “a litigant who has already filed a notice making his intent to appeal clear, no second notice of appeal is required.”

“Instead, the original notice relates forward to the date reopening is granted,” she wrote.

Justice Gorsuch wrote in his dissent that he would have dismissed the case as “improvidently granted” because changes in court rules that address the situation described in the case may be coming soon.

A court may dismiss a case as “improvidently granted” when it later decides that it should not have agreed to hear the case at all.

Gorsuch said the Advisory Committee on Appellate Rules is currently studying whether to make changes to the appeals court rule about notices of appeal.

The Advisory Committee on Appellate Rules is a group within the Judicial Conference of the United States that advises on changes to the Federal Rules of Appellate Procedure. The Judicial Conference of the United States, which was created by Congress, is the national policymaking body for federal courts.

Instead of taking up problems the committee “can solve and has announced its interest in solving … I believe the wiser and more efficient course is to let the Committee get on with its work,” Gorsuch said.

The Supreme Court reversed the Fourth Circuit and sent the case back to that court “for further proceedings consistent with this opinion.”

This article by Matthew Vadum appeared June 12, 2025, in The Epoch Times.