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).
CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT · Argued November 4, 2025
Parties — Petitioner: CONEY ISLAND AUTO PARTS UNLIMITED, INC. · Respondent: BURTON, chapter 7 trustee for VISTA-PRO AUTOMOTIVE, LLC
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.
Who prevailed — The respondent prevailed because the Court affirmed the lower court's denial of the petitioner's motion to vacate the judgment.
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.*