Robert Sherman v. Patrick Quinn, 668 F.3d 421

Sherman challenges line-item appropriations in Illinois Public Act 96-39 (2009) for grants to religious organizations under the Build Illinois Bond Fund.
District court dismissed the complaint, ruling Eleventh Amendment barriers, lack of standing, and no facial or as-applied Establishment Clause violation; denied leave to amend.
District court found the line-item grants not yet dispersed, so as-applied challenge was not ripe; Lemon test applied to facial challenge.
Sherman sought relief and later moved for reconsideration; district court denied 59(e) motion.
Sherman filed a notice of appeal within 30 days of judgment extensions; defendants moved for extension denial and later appealed the district orders.
The panel held the district court abused its discretion by extending the deadline, resulting in dismissal for lack of jurisdiction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the extension of time to appeal was proper	Sherman argues excusable neglect or good cause justify extension.	Defendants contend extension was improper; only excusable neglect or good cause under Rule 4(a)(5) apply and were not shown.	Extension abused; appeal untimely; lack of jurisdiction.

Lemon v. Kurtzman, 403 U.S. 602 (1971) (establishment clause framework)
Parke-Chapley Const. Co. v. Cherrington, 865 F.2d 907 (7th Cir. 1989) (distinct good cause standards for extensions (pre-2002 amendments))
Lorenzen v. Employees Retirement Plan, 896 F.2d 228 (7th Cir. 1990) (explanation of extension standards; natural error when late)
McCarty v. Astrue, 528 F.3d 541 (7th Cir. 2008) (abuse of discretion standard for excusable neglect)
Pearson v. Gatto, 933 F.2d 521 (7th Cir. 1991) (district court may grant extension for overcommitment by counsel; good faith factor)
Redfield v. Continental Casualty Corp., 818 F.2d 596 (7th Cir. 1987) (counsel’s good faith and workload considerations in excusable neglect)