Case Explained: UNITED STATES OF AMERICA v. PATRICK TYLICKI

Court: United States Court of Appeals for the Fourth Circuit Filed: 2026-06-24 The fourth-circuit dismissed Patrick Tylicki’s appeal from the denial of his 28 U.S.C. § 2255 motion because he failed to obtain a certificate of appealability. The court held that an appeal in a habeas case is not permissible unless a circuit justice or judge issues such a certificate, which requires a “substantial showing of the denial of a constitutional right.” Under the applicable standard, when a district court denies relief on procedural grounds, the prisoner must demonstrate that both the dispositive procedural ruling and the underlying constitutional claim are debatable to reasonable jurists. Although the court independently verified its jurisdiction by determining that Tylicki’s notice of appeal was timely filed after the entry of a separate judgment, it concluded upon independent review of the record that Tylicki did not make the requisite showing to satisfy the certificate standard. Consequently, the court denied the motion for a certificate of appealability and dismissed the appeal without oral argument. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.