Supreme Court Holds Time Limit of Federal Rules Applies to Voidness Motions

In Coney Island Auto Parts Unlimited, Inc. v. Burton, 607 U.S. ___ (2026), the U.S. Supreme Court held that the reasonable-time limit in Federal Rule of Civil Procedure 60(c)(1) applies to a motion alleging that a judgment is void under Rule 60(b)(4).

Facts of the Case

Vista-Pro Automotive, LLC entered bankruptcy in 2014 and initiated adversarial proceedings against Coney Island Auto Parts Unlimited, Inc., to collect $50,000 in allegedly unpaid invoices. Vista-Pro attempted to serve process on Coney Island by mail but purportedly failed to comply with Federal Rule of Bankruptcy Procedure 7004(b)(3)’s mail-service requirements. Coney Island did not file an answer, and the Bankruptcy Court entered a default judgment.

Over the next six years, Vista-Pro’s bankruptcy trustee attempted to enforce the judgment. In 2021, a marshal seized funds from Coney Island’s bank account in satisfaction of the judgment. Coney Island filed a motion to vacate the judgment under Federal Rule of Civil Procedure 60, arguing that Vista-Pro’s failure to make proper service rendered the judgment void. The Bankruptcy Court denied relief, holding that Coney Island failed to abide by Rule 60’s requirement that parties make motions for relief within a “reasonable time.” The District Court and the Sixth Circuit Court of Appeals affirmed.

Supreme Court’s Decision

The Supreme Court unanimously affirmed, holding that that Rule 60(c)(1)’s reasonable-time limit applies to Rule 60(b)(4) voidness motions. Justice Samuel Alito wrote on behalf of the Court.

The Court’s opinion focused on the text of Rule 60(c)(1), with Justice Alito emphasizing that the Rule clearly states, “that a ‘motion under Rule 60(b) must be made within a reasonable time.’”He added: “Because a motion for relief from an allegedly void judgment is a ‘motion under Rule 60(b),’ the reasonable-time limit applies.”

The Supreme Court rejected the argument that a void judgment is a “legal nullity” and thus can be attacked at any time. “This argument cannot bear the weight that Coney Island and others have placed on it. Even if the passage of time cannot cure voidness, the same principle holds true for most legal errors. Nevertheless, statutes and rules routinely limit the time during which a party can seek relief from a judgment infected by error,” Justice Alito wrote. “Therefore, a party in Coney Island’s position would need to show that some principle of law, such as the Due Process Clause, gives a party the right to allege voidness at any time.”

The Supreme Court also rejected Coney Island’s argument that courts have historically allowed litigants to seek relief from void judgments at any time. According to Justice Alito, no such historical consensus exists, and in any event, for Rule 60(b) motions, the Rule’s text and structure take priority over historical practice.