Notice and appeal deadlines
Elhadj Alpha Mahmoud Souare v. Guzzo
In brief
- Where it stands
- Dismissed
Petition denied.
- What it’s about
- Elhadj Alpha Mahmoud Souare asked the Supreme Court to review whether Ohio could dismiss his appeal as late after the clerk allegedly failed to send required notice, and whether a retired judge’s authority to enter judgment was properly established.
- Who it affects
- Souare did not receive Supreme Court review; the Court did not decide whether the Ohio court’s notice or judge-assignment procedures violated due process.
Summary: written with AI from the case record.

What it's about
The Court refused to hear the case (denied review), so it did not decide those questions.
Souare’s filing linked the appeal deadline to Ohio’s rule about when the clerk must serve a judgment.
Question presented
1. Whether the Fourteenth Amendment's Due Process Clause permits a state court to dismiss an appeal as untimely where state law makes clerk service of judgment the jurisdictional trigger for appeal, yet the clerk failed to provide the notice required by Ohio Civ.R. 58(B) and Ohio App.R. 4(A)(3). 2. Whether due process is violated when a litigant is denied appellate review because of the State's own procedural failure to provide notice, thereby creating the type of procedural deprivation prohibited by Logan v. Zimmerman Brush Co., 455 U.S. 422 (1982). 3. Whether the entry of judgment by a retired judge whose assignment authority does not appear in the public record — while the same court subsequently obtained a documented Certificate of Assignment for a different judge in the same case — raises a substantial federal due process question concerning adjudicatory authority and lawful tribunal authorization under Lucia v. SEC, 585 U.S. 237 (2018), and Caperton v. A.T. Massey Coal Co., 556 U.S. 868 (2009).
Documents
Docket activity
New analysis added
AI analysis generated: Case Briefing
AI analysis generated: Decision Record
Case data updated: summary, question_presented, generation_metadata
Case data updated: question_presented, extraction_metadata
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Brief added: Petition
Sources
Primary materials plus reporting. Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.