Coney Island Auto Parts Unlimited, Inc. v. Burton
The Supreme Court unanimously ruled that a party challenging a court judgment as legally void must still act within a reasonable time — the same baseline deadline that applies to all other motions seeking relief from final court judgments.
The decision resolves a long-running split among federal appeals courts and means that waiting years after learning of an allegedly defective judgment — as the auto parts company here did — can forfeit the right to challenge it.
How it got here: The Bankruptcy Court denied Coney Island's motion to vacate as untimely; the District Court and Sixth Circuit affirmed; Coney Island asked the Supreme Court to resolve a split among the federal appeals courts.
The Case in Depth
What happened
Vista-Pro Automotive sued Coney Island Auto Parts in bankruptcy court to collect $50,000 in allegedly unpaid invoices, but apparently failed to follow the rules for mailing legal notice to the company. Coney Island never responded, and a default judgment was entered in 2015. Coney Island received a demand letter in 2016 notifying it of the judgment, but did nothing. In 2021, a marshal seized money from Coney Island's bank account to satisfy the judgment, and only then did Coney Island move to vacate it, arguing the improper service made the judgment void.
The question before the Court
Must a company that claims a court judgment against it was legally invalid from the start still file its challenge within a "reasonable time" under the federal court rules?
The Court's answer
Yes — a party that wants to challenge a court judgment as legally void must still file that challenge within a "reasonable time" under Federal Rule of Civil Procedure 60(c)(1). The rule's plain text says all Rule 60(b) motions must be filed within a reasonable time, and a motion claiming a judgment is void is a Rule 60(b) motion. There is no exception.
The Court also rejected the argument that void judgments are inherently different because time cannot cure a legal nullity. That same logic would apply to almost any legal error, yet deadlines routinely govern challenges to erroneous judgments. The flexible "reasonable time" standard already protects defendants who were never properly served — it allows courts to treat a delay as reasonable if a defendant didn't learn about the judgment until a creditor tried to enforce it. Coney Island simply waited too long even under that forgiving standard.
Curious how the Court got there? See the step-by-step legal reasoning →
Why it matters
Defendants who receive a court judgment against them — even one they believe was entered without proper notice or legal authority — cannot wait indefinitely before asking a court to throw it out. Businesses and individuals who discover old default judgments being enforced against them must act promptly once they learn of those judgments, or risk losing the right to challenge them entirely.
What changes now
The Sixth Circuit's ruling stands, and Coney Island loses its challenge to the default judgment. Because the company did not argue below that its delay was actually reasonable under the circumstances, the Court did not address that question — it simply affirmed on the threshold issue that the time limit applies. The decision settles a split among federal appeals courts and provides a uniform rule: void-judgment challenges under Rule 60(b)(4) must be brought within a reasonable time.
What this does not decide
The Court did not decide whether the allegedly defective service in this case actually rendered the judgment void, or whether Coney Island's specific delay was or was not "reasonable." It also did not address other routes for challenging void judgments outside of Rule 60(b), which Rule 60(d) separately preserves.
Concurrences and dissents
How the Justices voted
Majority (8). Justice Alito (author), joined by Justice Roberts, Justice Thomas, Justice Kagan, Justice Gorsuch, Justice Kavanaugh, Justice Barrett, and Justice Jackson.
Separate writings (1). Justice Sotomayor (author of a concurrence).
Concurrence — Justice Sotomayor
Justice Sotomayor agreed that Rule 60(c)(1)'s reasonable-time limit applies to void-judgment motions, and she joined the judgment. She wrote separately to object that the majority went further than necessary by discussing whether a due-process challenge to the time limit might ever succeed — an argument Coney Island never raised before any court and expressly disclaimed in the Supreme Court. She would have resolved the case on the text and structure of Rule 60 alone, without speculating about constitutional questions no party asked the Court to decide. Read the full concurrence →
How the Court got there
The legal reasoning, step by step
- The Court began with Rule 60(c)(1)'s plain text: 'a motion under Rule 60(b) must be made within a reasonable time.' A Rule 60(b)(4) motion claiming a judgment is void is, by definition, a 'motion under Rule 60(b)' — so the reasonable-time limit applies to it the same as to any other motion under that rule.
- The rule's structure reinforces the plain-text reading. When the drafters of Rule 60 wanted to override the default reasonable-time limit, they did so explicitly — Rule 60(c)(1) separately imposes a hard one-year cap on motions alleging mistake, newly discovered evidence, or fraud. The absence of any analogous carve-out for void-judgment motions confirms that no special unlimited-time exception was intended.
- The Court rejected the argument that a void judgment is a 'legal nullity' that can never be ratified by the passage of time, and therefore should never be subject to a deadline. While that proposition may be true in a technical sense, it describes most legal errors — and statutes and rules routinely impose time limits on challenging erroneous judgments. To escape a deadline on that logic, a party would need to point to a constitutional principle (like due process) requiring courts to stay open to void-judgment challenges forever. Coney Island expressly disclaimed any such argument.
- The Court addressed the concern that defendants who were never properly served might not learn about a lawsuit until years later, making any time limit seem unfair. Rule 60(c)(1)'s flexible 'reasonable time' standard already accounts for this — unlike a fixed deadline, it lets courts ask what was reasonable given the particular defendant's circumstances. In a default-judgment case, it may well be reasonable for a defendant to wait until a creditor tries to enforce the judgment before filing a challenge.
- The Court rejected Coney Island's historical-practice argument, finding no clear consensus that courts have ever allowed void-judgment challenges at literally any time — some courts historically applied laches or other time limits even in void-judgment cases. The Court also held that for Rule 60(b) motions, the rule's text and structure take priority over historical practice in any event, and that policy arguments, drafting history, and the canon of constitutional avoidance only come into play when a rule's language is genuinely ambiguous — which Rule 60(c)(1)'s language is not.
Doctrinal impact
Cases affected by this decision
Reaffirms Kemp v. United States (596 U. S. 528)
Cited to confirm that all Rule 60(b) motions, without exception, must be filed within a reasonable time.
Distinguishes Insurance Corp. of Ireland v. Compagnie des Bauxites de Guinee (456 U. S. 694)
The Court read this case as actually supporting time limits on void-judgment challenges, not exempting them.