We will hear an argument next in case 24275, Parish v. United States. Ms. Rice.

Good morning, Mr. Chief Justice, and may it please the Court.

Courts have long recognized that notices of appeal that are filed early take effect when an appeal clock starts running,

so long is there otherwise sufficient and no one's prejudice.

That principle is consistent with the functional approach this Court takes to notices of

appeal.

It was applied in first tier, Lemke and Luckenbach, and no one disputes, not the Fourth

Circuit, not Mr. Houston, not any other court, to my knowledge,

but it's consistent with 2107A, which sets the notice of appeal requirement and the default deadline for filing.

The Fourth Circuit was wrong to read subsection C as displacing the ripening principle

and requiring a second notice in the reopening context only.

The principle applies to notices filed after final judgment, just like it does to notices filed before.

That's why courts have consistently held the notices of appeal ripen when an extension is granted under 2107C's first sentence.

Nothing in the second sentence suggests that notices of appeal work differently for reaffirmed. is granted under 2107C's first sentence.

Nothing in the second sentence suggests that notices of appeal work differently for reopening,

and requiring a duplicative notice of appeal would serve no conceivable purpose.

I welcome the Court's questions.

So you don't think that there's a material difference between filing a notice of appeal prematurely as opposed to too late?

I do think there's a difference, Justice Thomas.

I think filing a notice of appeal too late, as this Court held in Bowles, is a jurisdictional problem.

So why isn't this notice of appeal too late? The notice of appeal is certainly too late with respect to the original appeal period.

If nothing else had happened, there would be no argument that the notice of appeal was timely.

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