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Williams v. Truesdell - Appeal Dismissed for Untimely Filing

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Filed February 23rd, 2026
Detected February 24th, 2026
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Summary

The Fourth Circuit Court of Appeals dismissed Kristen Williams's appeal against Phillip Truesdell and others. The dismissal was based on the appellant's failure to file the notice of appeal within the 30-day jurisdictional deadline after the district court's order.

What changed

The Fourth Circuit Court of Appeals has dismissed the appeal in Kristen Williams v. Phillip Truesdell, et al. The dismissal is due to the appellant, Kristen Williams, failing to file her notice of appeal within the mandatory 30-day period following the district court's July 28, 2025 order. The appeal period expired on August 27, 2025, but the notice of appeal was not filed until September 3, 2025, rendering it untimely and a jurisdictional bar.

This decision means the appellant's case will not be heard on its merits by the Fourth Circuit. For legal professionals and parties involved in litigation, this serves as a critical reminder of the strict adherence required for appellate filing deadlines. Failure to comply with Rule 4(a) of the Federal Rules of Appellate Procedure can result in the dismissal of an appeal, regardless of the underlying merits of the case.

What to do next

  1. Review internal procedures for tracking appellate filing deadlines.
  2. Ensure all notices of appeal are filed within the 30-day window prescribed by Fed. R. App. P. 4(a)(1)(A).

Source document (simplified)

UNPUBLISHED UNITED STATES COURT OF AP PEALS FOR THE FOURTH CIRCUIT No. 25 - 2070 KRISTEN WILLIAM S, Plaintiff - Appellant, v. PHILLIP TRUESDELL, Deceased; AUDREY COPELAND, As Phillip ’ s Power of Authorities; RONALD COPELAND, As Ph illip ’ s Power of Authorities; GROVER BEAU SEATON, Former Attorney; SHEILA R. MIMS, Former Attorney; JASON R. WHEELER, App ointed GAL; TO DD J. MANLEY; DI AMOND GORDON, Case Worker; TERRY PALM, Su pervis or; SOUTH C AROLINA D EPARTMEN T OF SOCIAL SERVI CES; ESTATE OF PHIL LIP TRU ESDELL; HANNAH LASSITER; SI ERRA REGISTER; VERNETTE TO LLIVER; NAJLA C. WRIGHT; SALLY R. YOUN G; KYRA MCMIL LAN; DEBBIE POLI TANO, Defendants - Appellees. Appeal from the United States District Court for the District of South Carolin a, at Charleston. Bruce H. Hend ricks, District Judge. (2:25 - cv - 003 01 - BHH) Submitted: February 19, 202 6 Decided: February 23, 2026 Before WYNN and HARRIS, Circuit Judges, and TRAXLER, Senior Circuit Judge. Dismissed by unpublished per curiam opinion. Kristen Williams, Appellant Pro Se. Sarah Cameron Frierson, Joseph Calhoun Watson, ROBINSO N GRAY STEPP & LA FFITTE, LLC, Columbia, South Carolina; Carmen

2 Vaughn Ganjehsani, Columbia, South Caro lina, Payt on Hoover, RICHARDS ON PLOWDEN & ROBINSON, PA, Mount Pleasant, South Carolina; Stephen L ynwood Brown, Graydon V. Olive, IV, CLEMEN T RIVERS, LLP, Charleston, South Carolina, for Appellee s. Unpublished opinions are not binding p recedent in this circuit.

3 PER CURIAM: Kristen Williams seeks to appeal the district court’s order accepting th e recommendation of the magistrate judge and dismissing Williams’s 42 U.S. C. § 1983 action for lack of subject matter jurisdiction and failure to state a claim upon which relief c ould be granted. We dismiss the appeal for lack of jurisdictio n because the notice of appeal was not timely filed. In civil cases, parties have 30 days after the entry of the district court’s final judgment or order to note an appeal, Fed. R. App. P. 4(a)(1)(A), unless the district court extends the appeal period under Fed. R. App. P. 4(a)(5) or reopens the appeal peri od under Fed. R. App. P. 4(a)(6). “[T]he timely filing o f a notice of appeal in a civi l case is a jurisdictional requirement.” Bow les v. Russell, 551 U.S. 205, 214 (2 007). The district court entered its ord er on July 28, 2025, and the app eal period expired on August 27, 2025. Williams filed the notice of appeal on September 3, 2025. Becau se Williams failed to file a timely notice of appeal or to obtain an extension or reopening of the appeal period, we dismiss the appeal. We dispense with oral argument becau se the facts and legal contentions are adequately presented in the materials before this court and argument would not aid the decisional process. DISMISSED

Source

Analysis generated by AI. Source diff and links are from the original.

Classification

Agency
Federal and State Courts
Filed
February 23rd, 2026
Instrument
Enforcement
Legal weight
Non-binding
Stage
Final
Change scope
Minor

Who this affects

Applies to
Courts Legal professionals
Geographic scope
National (US)

Taxonomy

Primary area
Judicial Administration
Operational domain
Legal
Topics
Civil Procedure Appellate Procedure

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