The First Circuit has declined to apply the mailbox rule to a detainee whose petition for review was mailed prior to the filing deadline by his spouse, when the petition did not arrive at the clerk’s office until after the deadline had passed.
The full text of Ramos Goncalves v. Bondi can be found here:
www.ca1.uscourts.gov/sites/ca1/files/opnfiles/24-1511P-01A.pdf