Prison-Mailbox Rule Requires Accurate Addressing: United States v. Cargo

Introduction

United States v. Matthew Cargo is a Seventh Circuit decision issued April 18, 2025, clarifying that a notice of appeal handed to prison authorities must be correctly addressed to the district court to qualify under the prison-mailbox rule. Matthew Cargo, a federal inmate, attempted to appeal his conviction by mailing a notice of appeal on July 22, 2020. He misaddressed the courthouse street name, causing the Postal Service to return the envelope. Discovering the error only in November 2024, Cargo re-mailed the same notice—four years after his appeal deadline had passed. The Government moved to dismiss for untimeliness, and the Seventh Circuit agreed, holding that inaccurate addressing defeats the prison-mailbox rule regardless of the inmate’s intent or the timeliness of the initial tender.

Summary of the Judgment

The court dismissed Mr. Cargo’s appeal as untimely. It concluded that:

The deadline for a criminal defendant to file a notice of appeal is 14 days after entry of judgment (Fed. R. App. P. 4(b)(1)(A)).
Under the prison-mailbox rule (Houston v. Lack, 487 U.S. 266 (1988)), a pro se inmate’s pleading is “filed” when tendered to prison authorities for mailing.
However, tender alone is insufficient if the envelope is not correctly addressed and never reaches—and cannot be forwarded to—the district court.
Cargo’s misaddressed envelope never left the sender and thus never constituted a “filing” under Houston.
The re-mailing in November 2024, long after the deadline, was untimely and could not revive his appeal rights.

Analysis

1. Precedents Cited

Houston v. Lack, 487 U.S. 266 (1988): Established that a pro se prisoner’s notice of appeal is “filed” when handed to prison authorities for mailing, rather than when received by the court clerk.
Fed. R. App. P. 4(b)(1)(A): Sets a 14-day deadline to file a criminal appeal.
Ray v. Clements, 700 F.3d 993 (7th Cir. 2012): Held that lack of prisoner diligence in monitoring delivery does not undo an otherwise timely Houston filing.
Saxon v. Lashbrook, 873 F.3d 982 (7th Cir. 2017): Applied the mailbox rule even where the notice was mistakenly addressed to the court of appeals rather than the district court, relying on Fed. R. App. P. 4(d).
Circuit cases from the Second, Fourth, Fifth, Sixth and Ninth Circuits (Knickerbocker v. Artuz; Wilder v. Chairman; Dison v. Whitley; Cook v. Stegall; Baeta v. Sonchik) which have uniformly declined to extend Houston protection to missent notices that never reach any court clerk.

2. Legal Reasoning

The Seventh Circuit began with the well-settled rule that under Houston v. Lack, a pro se prisoner’s filing is effective upon delivery to prison authorities. But the court identified a critical caveat in Houston’s language: the notice must be “delivered for forwarding to the district court.” 487 U.S. at 273. Cargo’s misaddressed envelope was returned as “not deliverable as addressed” and thus never forwarded. The panel declined to treat prison officials as equivalent to a court clerk such that mere tender—absent correct addressing—would suffice.

The court distinguished cases like Saxon and Baeta—where incorrect addressing nonetheless resulted in the court receiving and filing the documents—from Cargo’s case, where the mail never left the sender. Several sister circuits have similarly held that the prison-mailbox rule does not protect misaddressed mail that does not reach the clerk.

3. Impact

United States v. Cargo establishes a precise limitation on the prison-mailbox rule:

Prisoners must not only tender their notices of appeal by the deadline but also correctly address them to ensure actual delivery to the district court.
Inaccurate or incomplete addressing that results in non-delivery precludes the Houston filing date.
Counsel is thus strongly encouraged, and perhaps required, to file notices of appeal to avoid technical missteps beyond the inmate’s control.

Lower courts will now require proof not only of timely tender and prepaid postage but also of proper addressing. This decision may lead detention facilities to adopt stricter mailing checks and prisoner-counsel communication protocols.

Complex Concepts Simplified

Prison-Mailbox Rule: An exception under which a pro se inmate’s court filing is deemed filed on the date he gives it to prison authorities, rather than the date the court clerk receives it.
Notice of Appeal Deadline: In federal criminal cases, a defendant has 14 days from the entry of final judgment to file a notice of appeal (Fed. R. App. P. 4(b)(1)(A)).
Filing vs. Delivery: "Filing" occurs when the court clerk receives a document. Under Houston, a pro se prisoner’s “filing” occurs upon tender to prison staff—but only if the envelope is correctly addressed and actually forwarded to the clerk.

Conclusion

United States v. Cargo refines the prison-mailbox rule by emphasizing the necessity of accurate addressing. Prisoners cannot rely solely on tendering mail to authorities; they must ensure their notices of appeal reach the district court. The decision underscores the importance of counsel representation to avoid unintended forfeitures of appeal rights and directs lower courts and correctional institutions to pay greater attention to mailing accuracy in pro se prisoner cases.