United States v. Rodercus Freeman

CourtCourt of Appeals for the Sixth Circuit
DecidedDecember 17, 2025
Docket25-5472
StatusUnpublished

This text of United States v. Rodercus Freeman (United States v. Rodercus Freeman) is published on Counsel Stack Legal Research, covering Court of Appeals for the Sixth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States v. Rodercus Freeman, (6th Cir. 2025).

Opinion

NOT RECOMMENDED FOR PUBLICATION File Name: 25a0585n.06

No. 25-5472

UNITED STATES COURT OF APPEALS FILED FOR THE SIXTH CIRCUIT Dec 17, 2025 KELLY L. STEPHENS, Clerk ) UNITED STATES OF AMERICA, ) Plaintiff-Appellee, ) ON APPEAL FROM THE ) UNITED STATES DISTRICT v. ) COURT FOR THE WESTERN ) DISTRICT OF TENNESSEE RODERCUS FREEMAN, ) Defendant-Appellant. ) OPINION ) )

Before: STRANCH, BUSH, and READLER, Circuit Judges.

JOHN K. BUSH, Circuit Judge. Rodercus Freeman filed an untimely appeal. The

district court then denied Freeman’s motion to extend the time for taking his appeal. The district

court did not abuse its discretion by denying this motion, so we AFFIRM.

I.

A jury convicted Freeman of one count of bank robbery and one count of attempted credit

union robbery. Freeman then fired his attorney during a post-conviction status conference and

chose to represent himself at sentencing. Three months later, on April 25, 2023, Freeman

proceeded to sentencing. At the end of the sentencing hearing, the district court told Freeman that

he “need[ed] to file [his] notice of appeal within 14 days.” R. 114, Sentencing Hr’g Tr., PageID

1521. Freeman said that he understood. But Freeman’s notice of appeal was not received by the

district court and docketed until over a month later on May 30, 2023. No. 25-5472, United States v. Freeman

When the fourteen-day timer began running, Freeman was a prisoner at Shelby County

Correctional Center. On May 4, 2023, prison officials began prepping Freeman for transfer. He

was finally transferred to the Oklahoma City Federal Center on May 8, 2023. The record does not

indicate whether Freeman knew of this transfer in advance. Freeman claims that after his transfer,

he was in lockdown for some unstated number of days. And after this ended, he promptly mailed

his notice of appeal on May 24, 2023, which asked for “equitable tolling” for the late filing.

We received this initial appeal and remanded to allow the district court to determine in the

first instance whether an extension of time to appeal should be granted for good cause or excusable

neglect. After requesting and receiving briefing on the issue, the district court denied Freeman’s

motion for an extension of time to file his notice of appeal. Freeman now appeals from this denial.

II.

We review the denial of a motion to extend the time to appeal in a criminal case for abuse

of discretion. United States v. Hills, 27 F.4th 1155, 1172 (6th Cir. 2022). A district court may

extend the timeline for filing a late notice of appeal by thirty days with or without motion and

notice “[u]pon a finding of excusable neglect or good cause” for the appellant’s failure to timely

file. Fed. R. App. P. 4(b)(4). The time period set forth in Rule 4(b) for filing a notice of appeal is

not jurisdictional, but it is a mandatory claim-processing rule that must be enforced if raised by

the government. United States v. Gaytan-Garza, 652 F.3d 680, 681 (6th Cir. 2011) (per curiam).

“Good cause will be found where forces beyond the control of the appellant prevented

[him] from filing a timely notice of appeal.” Hills, 27 F.4th at 1172 (quoting Nicholson v. City of

Warren, 467 F.3d 525, 526 (6th Cir. 2006)). To examine excusable neglect, we balance four

factors: (1) “prejudice to the other party,” (2) “the length of the delay and potential impact on the

proceedings,” (3) “the reason for the delay, including whether it was within the party’s reasonable

2 No. 25-5472, United States v. Freeman

control,” and (4) “whether the movant acted in good faith.” Hills, 27 F.4th at 1172 (citing Pioneer

Inv. Servs. Co. v. Brunswick Assocs. Ltd., 507 U.S 380, 395 (1993); see also Stutson v. United

States, 516 U.S. 193, 195–97 (1996) (discussing Pioneer’s application in criminal cases)). But

these factors do not carry equal weight—“the excuse given for the late filing must have the greatest

import.” United States v. Munoz, 605 F.3d 359, 372 (6th Cir. 2010) (quoting Lowry v. McDonnell

Douglas Corp., 211 F.3d 457, 463 (8th Cir. 2000)). Even so, the Supreme Court has said that

neglect need not be “caused by circumstances beyond the control of the movant” to be excusable

and a finding of sufficient innocence on the part of the movant is not a condition precedent to our

obligation to consider the other equitable factors. Pioneer, 507 U.S. at 392, 395 n. 14.

III.

In this appeal, Freeman argues that the district court abused its discretion by concluding

that Freeman did not establish good cause or excusable neglect. Given our precedent on these

issues, we have no difficulty affirming the district court.

A.

Freeman makes two arguments for why he had good cause for his untimely notice of

appeal: (1) The record does not show when he received the judgment from the district court, and

(2) he had only nine days to file prior to his transfer, not fourteen, and he was entitled to the entire

time. We reject each argument in turn.

Turning to the first argument. Freeman does not affirmatively state that he did not receive

the judgment; he notes only that the record is unclear. Pointing to an unclear record does not

“provide details about [his] prohibitive circumstance.” United States v. Douglas, 746 F. App’x

465, 467 (6th Cir. 2018). Without these details, we cannot conclude that good cause existed on

this basis.

3 No. 25-5472, United States v. Freeman

Further, Freeman had actual notice of the judgment, even if he did not receive a physical

copy of it on the day it was docketed. The district court told Freeman during the sentencing hearing

that Freeman would have fourteen days to file a notice of appeal, and Freeman said that he

understood. No matter when Freeman received the judgment, he knew the timeline for filing his

notice of appeal. The district court did not abuse its discretion in rejecting this argument.

Turning to the second argument, Douglas resolves this issue. In Douglas, the defendant

had five days between his sentencing hearing and reporting to jail. 746 F. App’x at 467. Because

the defendant had those five days, he did not have “a complete inability to file” his notice of appeal,

which can establish a finding of good cause. Id. (quoting Proctor v. N. Lakes Cmty. Mental Health,

560 F. App’x 453, 457 (6th Cir. 2014)). The defendant there, like Freeman, also failed to provide

details about any prohibitive circumstances that kept him from filing. Id.

Freeman had nine days prior to his incarceration where he could have filed his notice of

appeal. This shows that he did not have a “complete inability to file.” Id. (citation modified).

Freeman also does not explain why he could not have filed during that nine-day window. These

are the exact circumstances from Douglas, and Freeman does not offer any reason why the result

here should differ.

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Related

Stutson v. United States
516 U.S. 193 (Supreme Court, 1996)
United States v. Munoz
605 F.3d 359 (Sixth Circuit, 2010)
United States v. Gaytan-Garza
652 F.3d 680 (Sixth Circuit, 2011)
Nicholson v. City of Warren
467 F.3d 525 (Sixth Circuit, 2006)
Proctor v. Northern Lakes Community Mental Health
560 F. App'x 453 (Sixth Circuit, 2014)

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United States v. Rodercus Freeman, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-rodercus-freeman-ca6-2025.