The U.S. Court of Appeals for the Eighth Circuit dismissed an employment discrimination case after the plaintiff missed a critical filing deadline, highlighting the strict procedural requirements that govern federal appeals.
Darran Farmer, a former employee of FilmTec Corporation, sued his employer and its parent company DuPont De Nemours, Inc., alleging employment discrimination and retaliation based on his disability and race following his termination. The U.S. District Court for the District of Minnesota granted summary judgment to the defendants on all claims and entered judgment on Sept. 20, 2024.
Under Federal Rule of Appellate Procedure 4(a)(1)(A), Farmer had 30 days from the entry of judgment to file his notice of appeal. However, instead of filing an immediate appeal, Farmer chose a different strategy that ultimately proved unsuccessful.
On Oct. 17, 2024—28 days after the district court entered judgment—Farmer sent a letter to the district court requesting permission to file a motion for reconsideration under District of Minnesota Local Rule 7.1(j). This request came just two days before his appeal deadline would have expired.
The district court denied Farmer's request on Nov. 19, 2024, finding that no extraordinary circumstances warranted granting permission to file a motion for reconsideration. The denial came 60 days after the court had originally granted summary judgment to FilmTec and DuPont.
On the same day the district court denied his reconsideration request, Farmer filed his notice of appeal with the Eighth Circuit. However, this filing came 60 days after the original judgment was entered, well beyond the 30-day deadline established by federal appellate rules.
FilmTec subsequently filed a motion to dismiss the appeal as untimely, arguing that Farmer had failed to meet the mandatory filing deadline. The central legal question became whether Farmer's request for permission to file a motion for reconsideration had extended the time limit for filing his appeal.
The Eighth Circuit's per curiam opinion, filed Jan. 6, 2026, addressed this procedural dispute. The three-judge panel, consisting of Circuit Judges Smith, Kelly, and Grasz, considered whether the request for reconsideration affected the appeal deadline under federal procedural rules.
Federal appellate deadlines are generally strict and jurisdictional, meaning courts lack discretion to extend them in most circumstances. The timing requirements serve important judicial efficiency goals and provide certainty to all parties about when litigation has concluded.
The case illustrates the complex interplay between district court local rules and federal appellate procedure. While Farmer attempted to use Minnesota's local rules to seek reconsideration, this strategy did not successfully preserve his right to appeal to the federal circuit court.
Employment discrimination cases often involve multiple procedural hurdles that plaintiffs must navigate carefully. Beyond proving the merits of their claims, workers must comply with strict filing deadlines at both the administrative and judicial levels. Missing these deadlines can result in otherwise valid claims being dismissed on procedural grounds.
The dismissal represents a complete victory for FilmTec Corporation and DuPont De Nemours, Inc., as the appeals court did not reach the merits of Farmer's discrimination and retaliation claims. The companies successfully defended against the lawsuit through summary judgment in district court and then saw the case dismissed entirely when Farmer failed to timely appeal.
For employment law practitioners, the case serves as a reminder of the importance of strict deadline compliance in federal court. The 30-day appeal deadline under Rule 4(a)(1)(A) begins running immediately upon entry of judgment, regardless of any pending or contemplated post-judgment motions that have not been properly filed.
The case also highlights the limited circumstances under which district courts will grant permission to file late motions for reconsideration. Courts require extraordinary circumstances to justify departing from normal procedural timelines, a standard that was not met in Farmer's case.
The Eighth Circuit's decision was issued as an unpublished opinion, meaning it will not serve as binding precedent for future cases but reflects the court's application of established procedural rules. The ruling reinforces that federal appellate deadlines are mandatory and that creative procedural strategies cannot substitute for timely compliance with filing requirements.
Looking forward, the dismissal ends Farmer's federal court litigation against FilmTec and DuPont. The appeals court's ruling effectively validates the district court's summary judgment decision, as no higher court will review the merits of the discrimination and retaliation claims due to the procedural dismissal.