Docket 24-808
Coney Island Auto Parts Unlimited Inc. v. Burton
DecidedJan 20, 2026
9-0unanimous decision
Source: CourtListener.
Court rules deadline to challenge a "void" judgment must still be filed within a reasonable time
What it does
The ruling holds that a person seeking to overturn a court judgment on the grounds that it is void—for example because they were never properly served with legal papers—must still file that request within a "reasonable time" under Rule 60(c)(1). It rejects the idea that void judgments can be challenged at any point with no time limit at all.
Who benefits
Parties who obtained default judgments or other judgments long ago and want finality, such as creditors, bankruptcy trustees, and judgment holders who have relied on unchallenged judgments for years.
Who is affected
People and businesses who were never properly served with legal papers and later discover a default judgment against them, such as Coney Island Auto Parts, now must act promptly once they learn of the judgment or risk losing the ability to challenge it as void.
Practical impact
Litigants who believe a judgment against them is void—often due to improper service—must now file a Rule 60(b)(4) motion promptly after learning of the judgment and any enforcement efforts, rather than assuming they can wait indefinitely. Courts evaluating such motions will assess what counts as a "reasonable time" based on the circumstances, including when the party first learned of the judgment or enforcement actions against them, rather than applying no time limit or a fixed one-year deadline.
Majority reasoning
The Court reasoned that the plain text of Rule 60(c)(1) says a "motion under Rule 60(b) must be made within a reasonable time," and a motion alleging a judgment is void under Rule 60(b)(4) is still a "motion under Rule 60(b)," so the time limit applies. The Court noted that Rule 60 explicitly creates a one-year deadline for some types of motions (like those based on new evidence or fraud) but includes no similar exception carving out unlimited time for voidness claims, which suggests none was intended. The majority rejected the argument that because a void judgment is a "legal nullity," time cannot cure it, noting that many legal errors share this quality yet are still subject to deadlines, and no party showed a constitutional principle requiring unlimited time to challenge voidness. The Court also found no clear historical consensus that void judgments could always be challenged without any time limit, and held that Rule 60's text controls over historical practice or policy arguments where the text is otherwise clear.
Constitutional question
Does Federal Rule of Civil Procedure 60(c)(1)'s requirement that motions be filed within a "reasonable time" apply to motions under Rule 60(b)(4) that argue a judgment is void, or can such motions be filed at any time with no deadline?