Coney Island Auto Parts Unlimited v. Burton
Whether Federal Rule of Civil Procedure 60(c)(1)'s 'reasonable time' requirement applies to motions to vacate judgments that are void ab initio under Rule 60(b)(4), or whether such void judgments can be challenged at any time.
The Decision
Roberts
·
Thomas
·
Kagan
·
Gorsuch
·
Kavanaugh
·
Barrett
·
Jackson
·Decided January 20, 2026
Majority Opinion— Justice Alito
The Supreme Court held that when a party wants to challenge a court judgment as "void" (legally invalid) under Federal Rule of Civil Procedure 60(b)(4), they must still file their motion within a "reasonable time" as required by Rule 60(c)(1). The case involved Coney Island Auto Parts, which had a default judgment entered against it in 2015 after a bankruptcy-related lawsuit. Coney Island claimed it was never properly served with legal papers, which would make the judgment void. However, the company waited until 2021—after a marshal seized funds from its bank account—to challenge the judgment, despite evidence it had learned about the judgment as early as 2016.
Justice Alito, writing for an 8-1 majority, reasoned that the plain text of Rule 60 is clear: all motions under Rule 60(b), including those claiming a judgment is void, must be filed within a reasonable time. The Court rejected the argument that void judgments are so fundamentally defective that they can be challenged at any point without any time limit. While acknowledging that the passage of time cannot cure a void judgment, the Court noted that the same is true for most legal errors, yet time limits for challenging those errors are routine and accepted. The Court also pointed out that the "reasonable time" standard is flexible enough to protect parties who genuinely didn't know about a judgment—for instance, it might be reasonable for someone to wait until they actually learn about the judgment before challenging it.
The practical effect of this decision is that parties who believe a judgment against them is void—for example, because they were never properly served—cannot wait indefinitely to challenge it. They must act within a reasonable time after learning of the judgment. The Court resolved a split among federal appeals courts, with several circuits having previously held that no time limit applied to void-judgment challenges.
Concurring Opinions
Justice Sotomayor
Justice Sotomayor agreed with the Court's conclusion that the reasonable-time limit applies to motions challenging void judgments, finding that Rule 60's text and structure clearly require this result. However, she wrote separately because she believed the majority went too far by discussing whether the Due Process Clause might require courts to hear void-judgment challenges regardless of timing.
Sotomayor emphasized that Coney Island never raised a constitutional argument—not in the lower courts, not in the Sixth Circuit, and not before the Supreme Court, where the company expressly disclaimed any due process challenge. She argued that the Court should not opine on constitutional questions that no party has raised and that were not addressed by the courts below, consistent with the Court's general practice of not entertaining arguments not presented by the parties.
Background & Facts
Coney Island Auto Parts Unlimited had a default judgment entered against it in a bankruptcy proceeding involving Vista-Pro Automotive, LLC. The company claims it was never properly served and that the court lacked personal jurisdiction over it, making the judgment void from the very beginning (void ab initio). The Chapter 7 bankruptcy trustee, Jeanne Ann Burton, attempted to enforce the judgment over several years, including trying to seize bank assets.
Coney Island's owner, Daniel Beyda, says he first learned of the judgment in February 2021 and then sought counsel. However, the trustee had been attempting to enforce the debt since at least 2016, making seven separate attempts and spending thousands of dollars. Three lower courts — the bankruptcy court, the district court, and the Sixth Circuit Court of Appeals — all ruled that Coney Island waited too long to challenge the judgment and that the motion was untimely under Rule 60(c)(1), which requires such motions to be filed within a 'reasonable time.'
Notably, Coney Island did not argue in the courts below that its motion was filed within a reasonable time. Instead, it argued that the reasonable time requirement simply does not apply to judgments that are void ab initio. The Supreme Court took the case to resolve whether there is any time limit on challenging void judgments.
Why This Case Matters
This case addresses a fundamental tension in American civil procedure: can a judgment that was entered without proper jurisdiction — and is therefore considered legally void from the start — become immune from challenge simply because too much time has passed? The answer has major implications for finality of judgments, due process protections, and the practical operation of the federal court system.
Almost all federal courts of appeals and leading legal commentators have held that there is no time limit on vacating truly void judgments, but the Sixth Circuit ruled otherwise here. A ruling for the respondent would mean that even constitutionally defective judgments could become effectively permanent if not challenged quickly enough, while a ruling for the petitioner could allow decades-old judgments to be reopened. The case also tests the boundaries of textualism versus historical practice, as the plain text of Rule 60(c)(1) appears to impose a time limit while longstanding common law tradition holds that void judgments are perpetually subject to attack.
The Arguments
A judgment that is void ab initio — meaning it was a legal nullity from the moment it was entered due to lack of personal jurisdiction — can never become valid through the mere passage of time. Therefore, Rule 60(c)(1)'s 'reasonable time' requirement cannot logically apply to such judgments, and they may be challenged at any point.
- If a judgment is void immediately upon entry and remains so forever, there cannot be a deadline after which it suddenly springs to life and becomes enforceable.
- Courts have historically described void judgments as nullities lacking any legal effect, routinely vacating them without reference to time limits.
- Almost all courts of appeals and leading commentators have held that the reasonable time limitation does not apply to void judgments.
- The Due Process Clause independently prevents giving effect to a judgment entered without personal jurisdiction, regardless of procedural deadlines.
Key Exchanges with Justices
Justice Jackson
“What if we don't know whether it's a void judgment? Someone has to decide that, and shouldn't there be a procedural time limit on making that claim?”
Revealed the fundamental difficulty of petitioner's position: allowing unlimited time to claim voidness effectively lets parties unilaterally decide whether time limits apply.
Justice Alito
“Doesn't it seem strange that someone would have an unlimited amount of time to appeal from a judgment that's void ab initio?”
Showed even a sympathetic justice recognized the potentially extreme implications of petitioner's position.
Justice Sotomayor
“What do you do with the history that some state courts for decades have applied laches to this very situation, and doesn't that defeat your common law argument?”
Exposed a weakness in petitioner's historical argument and highlighted that the common law was not as uniform as petitioner claimed.
The plain text of Rule 60(c)(1) unambiguously requires that all motions under Rule 60(b) — including 60(b)(4) motions to vacate void judgments — must be filed within a 'reasonable time.' The phrase 'reasonable time' does not mean 'any time,' and the drafters could have placed void judgments under Rule 60(d) with no time limit if they intended that result.
- 'Reasonable time' by definition excludes unreasonable delays; 'any time' would include unreasonable time, which is the exact opposite of reasonable.
- The Advisory Committee notes show the drafters intended Rule 60 to be the exclusive mechanism for relief, abolishing prior common law writs and remedies.
- Three courts below all found petitioner's delay unreasonable, and petitioner never even argued its motion was timely.
- The trustee, an innocent party, spent years and thousands of dollars trying to collect on a facially valid judgment, creating real prejudice that the reasonable time standard is designed to address.
Key Exchanges with Justices
Justice Kagan
“Is there any category of cases in which a reasonable amount of time can, in fact, be any time?”
Respondent firmly held that 'reasonable time' can never mean 'any time,' though conceded that where there is no prejudice, the permissible time could be very long.
Justice Alito
“Shouldn't there be more flexibility regarding reasonableness when what is being contested is a judgment that's void ab initio?”
Respondent surprisingly said no — the nature of the defect does not inherently warrant more time, though default judgment circumstances and lack of notice might.
Justice Alito
“What do you say about Hewitt and the idea that a void ab initio judgment never existed?”
Respondent argued that the void ab initio concept describes the grounds for relief, not an exemption from procedural requirements, and noted that even void judgments can be given preclusive effect.
Precedent Cases Cited
Hewitt v. United States
Cited for its statement that a judgment void ab initio never existed and was 'erased from the historical record,' which petitioner argued supports unlimited time to challenge void judgments.
United States v. Beggerly
Cited by respondent for the proposition that Rule 60(d) independent actions are reserved to correct only gross miscarriages of injustice, limiting the availability of that alternative relief mechanism.
Austin v. Smith
Respondent identified this D.C. Circuit decision as the origin point from which five courts of appeals derived their rule that no time limit applies to void judgment challenges, noting it did not even mention Rule 60(c)(1).
United States v. Brogan
Cited by respondent as an example of the Supreme Court overruling a unanimous position of the courts of appeals based on textual analysis, suggesting the Court should do the same here.
Espinosa
Cited by respondent for its definition of void judgments, which includes certain jurisdictional defects and judgments lacking notice and opportunity to be heard.