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After a bench trial in federal court, the judge announced from the bench on May 1 that judgment would be entered for the defendant. The clerk entered a docket entry on May 2 stating, "Court finds for defendant; case closed," but no separate judgment document was entered. On May 10, the plaintiff filed a notice of appeal. On May 20, the plaintiff filed a timely Rule 59 motion to amend the judgment and make additional findings. The district court denied that motion on June 15. The plaintiff did not file a new notice of appeal after June 15.
The defendant moves to dismiss the appeal as premature and ineffective. The plaintiff argues that the May 10 notice should be treated as effective and that no new notice was needed because the Rule 59 motion was denied.
How should the appellate court analyze appeal timing? Discuss entry of judgment, the separate-document rule, premature notices, tolling motions, and whether the May 10 notice became effective after the Rule 59 motion was resolved.