Lawson v. Stephens, 20-10099

Paul Eugene Lawson, a former Texas prisoner, sought to reopen the time to appeal several pre-judgment motions the district court implicitly denied when it entered final judgment dismissing his civil-rights complaint on June 22, 2018.
Lawson filed a timely appeal of the judgment but later appealed denials of the pre-judgment motions; this court dismissed an earlier appeal in November 2019 for lack of jurisdiction because notices were untimely.
The district court denied Lawson’s later motion to reopen his time to appeal and denied in forma pauperis (IFP) status, certifying the appeal was not taken in good faith (i.e., frivolous).
Lawson claimed he never received notice of the denials of the pre-judgment motions and only learned they had been denied when this court dismissed his prior appeal in November 2019.
The Fifth Circuit found Lawson had been on notice: he filed notices to appeal the denials on April 4, 2019 and acknowledged the motions were denied when the June 22, 2018 final judgment issued; the district court did not abuse its discretion in refusing to reopen under Fed. R. App. P. 4(a)(6).
A later filing (a purported "complaint in interpleader" submitted three days after judgment) was not treated as an appealable order and was characterized as frivolous; the court declined to reopen time to appeal it.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Rule 4(a)(6) reopening is available because Lawson lacked notice of orders denying pre-judgment motions	Lawson: he did not receive Rule 77(d) notice of the orders and only learned of denials in Nov 2019	Defendants: Lawson was on notice; he acknowledged denials and filed notices to appeal earlier	Court: Denial of reopening affirmed; Lawson was notified and motion untimely
Timeliness of motions to reopen under Fed. R. App. P. 4(a)(6)	Lawson: sought reopening beyond allowed period after purported lack of notice	Defendants: filing deadlines were missed; no entitlement to extension	Court: District court did not abuse discretion in denying reopening
Whether the post-judgment "complaint in interpleader" created an appealable order	Lawson: sought to reopen time to appeal that filing	Defendants: filing was not a motion/order and was frivolous	Court: No appealable order; filing frivolous; reopening denied
Whether IFP certification (appeal not in good faith) was improper	Lawson: challenged district court’s certification by seeking IFP in this court	Defendants: certification proper because appeal lacked arguable merit	Court: IFP denied; appeal dismissed as frivolous

Baugh v. Taylor, 117 F.3d 197 (5th Cir. 1997) (standards for appellate IFP certification review)
Howard v. King, 707 F.2d 215 (5th Cir. 1983) (appeal frivolous if no legal points arguable on the merits)
Edionwe v. Bailey, 860 F.3d 287 (5th Cir. 2017) (prejudgment motions implicitly denied by final judgment)
Tollett v. City of Kemah, 285 F.3d 357 (5th Cir. 2002) (same—effect of final judgment on pre-judgment motions)
In re Jones, 970 F.2d 36 (5th Cir. 1992) (standard for reopening appeal period under Rule 4(a)(6))
Lawson v. United States Dep’t of Justice, [citation="819 F. App'x 260"] (5th Cir. 2020) (characterizing certain pro se motions as facially absurd)