Must a litigant who files a notice of appeal after the original deadline but before a court grants reopening under 28 U.S.C. § 2107(c) file a second notice of appeal? This question arises when a district court reopens the appeal period for 14 days following a finding that the party did not timely receive notice of judgment. The Court must determine if an initial, premature filing is sufficient to confer appellate jurisdiction.

• The original notice of appeal adequately communicated his intent to seek appellate review.
• A second notice would be redundant and amount to "empty paper shuffling."
• The Fourth Circuit should not deprive a litigant of the right to an appeal based on a procedural technicality.

• The term "reopen" in 28 U.S.C. § 2107(c) presumes the original period closed, meaning the new 14-day window is the only time an appeal can be commenced.
• The notice was "late" relative to the original deadline rather than "premature."
• A single filing cannot simultaneously function as a motion to reopen and a notice of appeal.

• The Court held that a litigant who files a notice of appeal after the original deadline but before reopening is granted does not need to file a second notice because the original notice relates forward to the date reopening is granted.
• Under 28 U.S.C. § 2107(a) and (b), civil notices of appeal must be filed within 30 or 60 days, a requirement that *Bowles v. Russell* deems jurisdictional.
• The Court applied the "relation-forward" rule, which holds that an adequate but premature notice relates forward to the entry of the document making the appeal possible.
• Relying on *Astoria Fed. Sav. & Loan Assn. v. Solimino*, the Court reasoned that Congress legislates against a background of common-law principles unless a contrary statutory purpose is evident.
• The Court cited *Foman v. Davis* and *Becker v. Montgomery* to emphasize that "decisions on the merits" should not be avoided based on "mere technicalities" when no genuine doubt exists about who is appealing, from what judgment, and to which court.
• The Court noted that 28 U.S.C. § 2107(c) does not explicitly terminate the relation-forward rule, and *Minerva Surgical, Inc. v. Hologic, Inc.* supports the inference that Congress expected such principles to apply.
• Federal Rules of Appellate Procedure 4(a)(2) and 4(a)(4) were found to codify the principle that premature notices relate forward to avoid creating "a trap for an unsuspecting litigant."
• The Court rejected the argument that Rule 4(a)(6)'s silence on relation-forward creates a negative implication prohibiting it, citing *NLRB v. SW General, Inc.* and *Scarborough v. Principi*.