Rule 81.05.Judgments, When Final--Premature Filing of Notice of Appeal--Computation of Time.

Rule 81.05 answers the question that Rule 81.04's ten-day appeal deadline depends on: when does a judgment become final? The baseline rule is simple. A civil judgment becomes final 30 days after it is entered, so long as no party has timely filed an authorized after-trial motion. Once that 30-day period runs out without such a motion, the ten-day clock to file a notice of appeal starts.

Filing a timely authorized after-trial motion changes the calculation. In that case the judgment becomes final at the earlier of two dates: 90 days from the date the last timely motion was filed, at which point any motion still not ruled on is deemed overruled by operation of the rule, or, if every motion has been ruled on, the date of the ruling on the last one decided or 30 days after entry of judgment, whichever of those two comes later. The 90-day period is computed the way Rule 78.06 directs. This holds regardless of whether the motion serves any purpose beyond asking the trial court for relief.

A notice of appeal filed too soon is not automatically lost. Rule 81.05(b) treats a premature notice of appeal as filed immediately after the judgment becomes final, so an appellant who jumps the gun does not have to start over.

A change effective July 1, 2026 narrows the definition without touching the deadlines themselves. The current version of the rule refers generally to an “authorized after-trial motion” without listing which motions qualify. The version taking effect that date adds a definition: an authorized after-trial motion means a motion seeking relief under Rule 72.01(b), Rule 73.01(d), or Rule 78. Everything else about the 30-day and 90-day framework stays the same; the amendment pins down which post-judgment motions can extend finality and, with it, the appeal clock.