United States v. Pierre Starks, 840 F.3d 960

Pierre Starks moved in district court for a sentence reduction under 18 U.S.C. § 3582(c)(2); the district court denied the motions on October 6, 2015.
Under Fed. R. App. P. 4(b)(1)(A)(i), Starks had 14 days after the entry of the order (until October 20) to file a notice of appeal in the district court.
Rule 4(b)(4) allows the district court to extend that 14‑day period for up to 30 additional days upon a finding of excusable neglect or good cause (here, until November 19).
Starks filed his notice of appeal on November 9 (timely under an extension but untimely under the 14‑day rule); the district court docketed the notice on November 13 but made no judicial finding of excusable neglect or good cause.
The government raised timeliness under Fed. R. App. P. 4(b); the Eighth Circuit held that docketing alone is a clerical act and cannot substitute for a judicial finding required by Rule 4(b)(4).
The court remanded so the district court can determine whether excusable neglect or good cause exists and, if so, whether to grant an extension up to 30 days from the original 14‑day period.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court’s docketing of Starks’ late notice of appeal operates as an extension under Fed. R. App. P. 4(b)(4)	Starks: docketing effectively granted the 30‑day extension, making his Nov. 9 filing timely	Government: appeal is untimely unless district court made a judicial finding of excusable neglect or good cause	Docketing is clerical and not a judicial finding; remand for the district court to determine excusable neglect or good cause and whether an extension is warranted

United States v. Watson, 623 F.3d 542 (8th Cir. 2010) (Rule 4(b) timeliness requirements are inflexible though not jurisdictional)
United States v. Anna, 843 F.2d 1146 (8th Cir. 1988) (district court must make a judicial finding of excusable neglect before extending appeal deadline; mere docketing is clerical)