Michael Armstrong v. City of Belleville, 834 F.3d 767

Armstrong filed a §1983 suit alleging unnecessary Taser use after he was struck by a bus and, while disoriented, failed to follow police commands.
Defendants moved for summary judgment; Armstrong did not respond and the district court granted judgment for defendants on May 1, 2014.
Armstrong failed to file a timely appeal; he later sought the district court’s relief claiming he had not received the summary-judgment motion or the order.
Armstrong filed multiple post-judgment motions (captioned under various rules) months after the judgment; the district court denied relief, finding Armstrong at fault for notice issues and that his motions were untimely or successive.
An appeal was filed via the prison law library’s electronic system; the court accepted the filing date under the prison-mailbox rule but held the only appealable order was the later denial of post-judgment relief, which did not warrant reopening the original judgment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Armstrong’s appeal was timely	Armstrong says he delivered his notice to the prison law library in time for a timely appeal	Defendants say he missed the statutory appeal deadlines and did not seek timely extension	Appeal treated as timely under mailbox rule for prison filings, but only as to the March 13 order; earlier deadlines were missed
Whether the initial post-judgment filing should have been treated as a Rule 59(e) motion	Armstrong argues the filing should be characterized as timely under Rule 59(e) so it would toll appeal time	Defendants contend it was not timely and thus properly treated as a Rule 60 or other post-judgment motion	Court held the filing was untimely for Rule 59(e); it was successive and did not toll appeal time
Proper rule for reopening appeal time when a litigant lacked notice of judgment	Armstrong sought relief under Rule 60(b) but argued lack of notice justified relief	Defendants maintained the district court acted within bounds in denying relief	Appellate Rule 4(a)(6) governs lack-of-notice reopenings; Armstrong’s request missed Rule 4(a)(6)’s deadlines, so reopening was unavailable
Whether successive post-judgment motions extend appeal time	Armstrong attempted to file successive motions to delay finality	Defendants argued successive motions do not extend appellate deadlines	Court held successive motions do not extend appeal time; litigants cannot delay by repeatedly filing post-judgment motions

Taylor v. Brown, 787 F.3d 851 (7th Cir. 2015) (prison mailbox rule applies when prisons route legal filings through law libraries)
Browder v. Director, Department of Corrections, 434 U.S. 257 (1978) (successive post-judgment motions do not extend the time to appeal)
York Group, Inc. v. Wuxi Taihu Tractor Co., 632 F.3d 399 (7th Cir. 2011) (post-judgment motion timing and appeal-finality principles discussed)