Docket 24-808
Coney Island Auto Parts Unlimited Inc. v. Burton
DecidedJan 20, 2026
8-1decision
Source: CourtListener.
Court rules time limits apply to motions challenging void judgments in federal court
Impact3/10
What it does
The Court held that any party seeking to challenge a court judgment as "void" — meaning legally invalid from the start — must still file that challenge within a "reasonable time" under Rule 60(c)(1). A party cannot wait indefinitely to raise a voidness claim simply because the underlying judgment may have been legally defective. The ruling resolves a longstanding disagreement among federal appeals courts on this question.
Who benefits
Parties who have obtained court judgments in their favor — including bankruptcy trustees and creditors — benefit because those judgments are now more protected from being thrown out years or decades later on procedural grounds.
Who is affected
Parties who were subject to a court judgment they believe was improperly entered — for example, because they were never properly served with legal papers — and who waited a significant amount of time before challenging it are now at risk of having their challenge dismissed as untimely.
Practical impact
Parties who believe a court judgment against them was void — for example, because they were never properly served with a lawsuit — must now act within a reasonable time after learning of the judgment to challenge it in court. In the bankruptcy context specifically, defendants who receive notice of a judgment or enforcement efforts cannot simply wait years before filing a motion to vacate. Courts will evaluate what counts as "reasonable" based on the specific facts, including when the challenging party first learned of the judgment.
Majority — Alito
Joined by: Roberts, Thomas, Kagan, Gorsuch, Kavanaugh, Barrett, Jackson
The majority held that the plain text of Rule 60(c)(1) is clear: any "motion under Rule 60(b)" must be filed within a reasonable time, and a motion challenging a void judgment is a Rule 60(b) motion, so the time limit applies. The Court also pointed to the structure of Rule 60 itself — the rule expressly sets a one-year hard deadline for certain types of motions (like those based on mistake or fraud), and if Congress had intended to create an unlimited-time exception for voidness claims, it would have said so explicitly. The majority rejected the argument that because a void judgment is a "legal nullity," time can never run out to challenge it, noting that most legal errors do not cure themselves over time yet are still subject to filing deadlines. The Court also warned that accepting the opposite rule — that voidness claims can be raised at any time — would lead to extreme results, such as allowing parties to ignore appeal deadlines whenever they dispute a court's jurisdiction. Finally, the majority found that the "reasonable time" standard already accommodates defendants who did not learn about a judgment until much later, such as those who never received proper notice, because what counts as "reasonable" can account for when the party actually found out.
Dissent reasoning
Justice Sotomayor agreed with the outcome — that the reasonable-time limit applies — but wrote separately to object to one part of the majority's reasoning. She argued that the majority went out of its way to address whether a due process constitutional challenge to the time limit might or might not succeed, even though no party raised that argument at any stage of the case. Coney Island explicitly told the Court it was not making a constitutional argument, and the lower courts never considered one. Justice Sotomayor emphasized that the Court's standard practice is not to address arguments that no party has raised, and she saw no unusual circumstances here that would justify departing from that practice.
Constitutional question
Does the "reasonable time" deadline in Federal Rule of Civil Procedure 60(c)(1) apply to a motion asking a court to throw out a judgment on the grounds that it is void — specifically under Rule 60(b)(4)?