Coney Island Auto Parts Unlimited, Inc. v. Burton, Chapter 7 Trustee for Vista-Pro Automotive, LLC
No. 24-808 · Decided January 20, 2026 · affirmed
Does the "reasonable time" requirement of Federal Rule of Civil Procedure 60(c)(1) apply to motions seeking relief from a void judgment under Rule 60(b)(4)? Federal Rule of Civil Procedure 60(c)(1)'s requirement that motions be made within a "reasonable time" applies to motions seeking relief from a void judgment under Rule 60(b)(4).
Vote & lineup9–0 (unanimous) on the judgment. Alito delivered the opinion of the Court, joined by Roberts, Thomas, Kagan, Gorsuch, Kavanaugh, Barrett, Jackson (8). Concurrence(s): Sotomayor.
The question
Does the "reasonable time" requirement of Federal Rule of Civil Procedure 60(c)(1) apply to motions seeking relief from a void judgment under Rule 60(b)(4)? The case involves a default judgment where the petitioner claims improper service under Federal Rule of Bankruptcy Procedure 7004(b)(3) rendered the judgment void. The Court must determine if such a motion is subject to the time limits set forth in Rule 60(c)(1).
Petitioner's argument
- A void judgment is a "legal nullity" under *United Student Aid Funds, Inc. v. Espinosa*, meaning the passage of time cannot transform it into an enforceable judgment.
- Courts have historically allowed litigants to seek relief from void judgments at any time, particularly when the issuing court lacked jurisdiction over the defendant.
- The failure to perform proper service is distinct from other legal errors because a party may not discover the proceedings until long after the judgment is entered.
- Policy concerns, the drafting history of Rule 60, and the canon of constitutional avoidance suggest that no time limit should apply to voidness claims.
Respondent's argument
- The plain text of Federal Rule of Civil Procedure 60(c)(1) explicitly states that a "motion under Rule 60(b) must be made within a reasonable time."
- Because a motion for relief from a void judgment is a "motion under Rule 60(b)," the reasonable-time limit applies to the petitioner.
- The structure of Rule 60 supports this interpretation because it provides specific time modifications for other grounds but contains no unlimited-time principle for voidness.
- Not stated.
The decision
- The Court held that Federal Rule of Civil Procedure 60(c)(1)'s reasonable-time limit applies to motions alleging a judgment is void under Rule 60(b)(4).
- The Court relied on the plain text of Rule 60(c)(1), which mandates that a "motion under Rule 60(b) must be made within a reasonable time," and noted that a motion under Rule 60(b)(4) is such a motion.
- Invoking *Kemp v. United States*, the Court affirmed that all Rule 60(b) motions must be filed within a reasonable time.
- The Court reasoned that the structure of Rule 60 supports this interpretation because while it expressly modifies the default limit for certain claims (e.g., a 1-year limit for mistake or fraud), it provides no such exception for voidness.
- The Court rejected the "legal nullity" argument from *United Student Aid Funds, Inc. v. Espinosa*, stating that statutes and rules routinely limit the time to seek relief from judgments infected by error.
- The Court found that the "reasonable time" standard already accommodates defendants who discover judgments late (such as during enforcement), making a perpetual window unnecessary.
- The Court determined that the Rule's "text and structure" take priority over historical practice, citing *Honeycutt v. United States*.
- The Court noted that *Insurance Corp. of Ireland v. Compagnie des Bauxites de Guinee* actually undermines the petitioner's position by recognizing that the "expression of legal rights is often subject to certain procedural rules."
- The Court declined to use drafting history or the canon of constitutional avoidance because those tools only apply when a Rule's language is ambiguous, citing *BP p.l.c. v. Mayor and City Council of Baltimore*, *Milner v. Department of Navy*, and *Van Buren v. United States*.
Separate opinions
Sotomayor, concurring
- Argues that the majority unnecessarily opines on the potential validity of a constitutional challenge to the "reasonable time" limit under the Due Process Clause.
- Bases this on the fact that the petitioner did not raise a constitutional attack below or before the Court, citing *Burwell v. Hobby Lobby Stores, Inc.*