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Prison Mailbox Rule Applies to Civil Detainees

by David M. Reutter

The Eleventh Circuit Court of Appeals held on September 18, 2019 that the “prison mailbox rule” applies to detainees held in a civil commitment center.

The ruling resulted from an appeal by Rayvon Boatman, a detainee at the Florida Civil Commitment Center (FCCC), which holds civilly committed sex offenders who have completed their prison sentences. Following an adverse ruling in district court, Boatman gave a pro se notice of appeal to FCCC officials to mail. At issue was the timeliness of that filing.

While the question of whether the mailbox rule in Fed.R.Civ.P. 4(c)(1) applies to a civilly committed person was one of first impression in the Eleventh Circuit, several other circuits have held the rule does apply to civil detainees. The Eleventh Circuit agreed with that position.

The mailbox rule makes a prisoner’s court filing timely “if it is deposited in the institution’s internal mail system on or before the last day for filing.” The appellate court found that civil detainees and civil detention centers fit within the definitions of the ordinary terms of “inmate” and “institution” used by Rule 4, and held the rule does not limit its application to persons imprisoned for criminal offenses.

After determining the mailbox rule applied to civil detainees, the Court of Appeals turned to whether it applied to Boatman’s situation. His notice was filed with the district court on April 25, 2019, which was beyond the 30-day deadline to appeal the court’s March 20, 2019 order. The notice itself was dated March 26, but the envelope was marked by FCCC as delivered to staff for mailing on April 23, 2019. The Eleventh Circuit said a pro se litigant is presumed, absent evidence to the contrary, to have submitted his notice of appeal on the date it was signed.

Following remand, the district court was ordered to determine whether Boatman had delivered his notice to FCCC officials for mailing within 30 days of the entry of judgment. See: Boatman v. Berreto, 938 F.3d 1275 (11th Cir. 2019). 

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Related legal case

Boatman v. Berreto