Hamer v. Neighborhood Hous. Servs. of Chi., 583 U.S. 17

Background

Hamer sued employers alleging employment discrimination; the District Court granted summary judgment and entered final judgment in September 2015.
The deadline to file a notice of appeal was October 14, 2015.
Before that deadline, Hamer’s counsel moved to withdraw and requested a two-month extension so she could obtain new counsel; the District Court granted withdrawal and extended the appeal deadline to December 14, 2015.
Respondents did not object in the District Court to the length of the extension.
On appeal, the Seventh Circuit sua sponte questioned timeliness; respondents then argued the appeal was untimely under Federal Rule of Appellate Procedure 4(a)(5)(C) (which limits extensions to 30 days). The Seventh Circuit dismissed for lack of jurisdiction.
The Supreme Court granted certiorari to decide whether a Rule-imposed time limit on extensions is jurisdictional or a claim-processing rule.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Rule 4(a)(5)(C)’s 30‑day limit on extensions is jurisdictional	Hamer: The Rule is not statutory; thus the limit is a claim-processing rule that can be forfeited	Respondents: The Rule reflects or tracks §2107 and should be treated as jurisdictional	The Rule’s limit is not jurisdictional; jurisdictional limits must originate in statute (not in a court rule)
Whether Bowles controls and requires dismissal when an appellate time limit is exceeded	Hamer: Bowles applied to a statutory time limit and is inapposite to a rule-based limit	Respondents: Bowles’ language about mandatory and jurisdictional time limits supports dismissal	Bowles governs only where Congress set the time limit; it was misapplied by the Seventh Circuit here
Whether courts must raise timeliness sua sponte when a rule-based limit is involved	Hamer: If rule-based, the limit can be forfeited and need not be raised sua sponte	Respondents: Timeliness implicates jurisdiction and so may be raised by the court	Court: Jurisdictional defects must be noticed sua sponte, but a rule-based (claim-processing) time limit does not carry that mandatory jurisdictional character
Whether the District Court’s failure to follow Rule time limits necessarily voids the extension	Hamer: Respondents forfeited objection by not raising it below; other equitable doctrines may apply	Respondents: District Court’s extension beyond Rule 4 is invalid and precludes jurisdiction	The Court did not decide forfeiture/equitable-exception questions; it remanded for further proceedings consistent with the holding that Rule 4(a)(5)(C) is nonjurisdictional

Key Cases Cited

Bowles v. Russell, 551 U.S. 205 (statement that statutory appeal deadlines are jurisdictional; involved §2107 limited by Congress)
Kontrick v. Ryan, 540 U.S. 443 (only Congress may define subject-matter jurisdiction; rules do not create or withdraw jurisdiction)
Henderson v. Shinseki, 562 U.S. 428 (distinguishing jurisdictional rules from claim-processing rules)
Eberhart v. United States, 546 U.S. 12 (claim-processing rules can be mandatory but forfeitable)
Griggs v. Provident Consumer Discount Co., 459 U.S. 56 (earlier characterization of appeal timing as "mandatory and jurisdictional")
Gonzalez v. Thaler, 565 U.S. 134 (clear‑statement rule for treating statutory limits as jurisdictional)
Arbaugh v. Y & H Corp., 546 U.S. 500 (statutory-interpretation framework for identifying jurisdictional provisions)