The Supreme Court’s recent decision in Coney Island Auto Parts Unlimited, Inc. v. Burton (1/20/26) resolved a decades-long split among circuit courts over whether motions to vacate allegedly void judgments are subject to time limitations. Eleven circuits prior to the decision held that the “reasonable time” standard was inapplicable to motions that sought to void initial judgements, such as those resting on procedural failures like defective service or notice, or lack of jurisdiction.
The Court however, sided with the lone Sixth Circuit, and held that parties seeking relief under Federal Rule of Civil Procedure 60(b)(4)—which allows courts to set aside “void” judgments—must still file their motions within a “reasonable time,” as required by Rule 60(c)(1). The Court’s decision has a meaningful procedural impact, particularly for litigants seeking to undo default judgments as well as for courts managing long-final cases.
The case arose from Vista-Pro Automotive, LLC’s 2014 bankruptcy. As part of the proceedings, Vista-Pro sued Coney Island Auto Parts to recover $50,000 in unpaid invoices. Vista-Pro attempted service by mail, but allegedly failed to comply with the technical requirements of Federal Rule of Bankruptcy Procedure 7004(b)(3). Coney Island never responded, and the bankruptcy court entered a default judgment in 2015.
In 2016, the trustee sent a demand letter to Coney Island’s chief executive officer, which lower courts found gave the company notice of both the judgment and enforcement efforts. Only after the trustee finally seized funds from Coney Island’s bank account in 2021, did Coney Island move to vacate the judgment, arguing it was void due to defective service.
The bankruptcy court denied relief, holding that the motion was untimely, and the district court and Sixth Circuit affirmed. The Sixth Circuit acknowledged that it was diverging from its sister circuits but maintained that its reading was faithful to the text of the rule which has been law of the land since 1946. Coney Island later appealed and the Supreme Court granted certiorari to decide whether Rule 60’s “reasonable time” requirement applies to motions alleging voidness.
Based on the clear operative language of Rule 60, the Court answered that question in the affirmative rejecting the argument that void judgments, as “legal nullities,” could be challenged at any time requiring a court to keep their doors open perpetually to allegations of voidness.
The takeaway from the Court’s decision is clear: act promptly or forever hold your peace. Ultimately, even claims that a judgment is void must be raised within a reasonable time or risk being lost forever.
