Court holds there is a time limit on challenging void judgments

The Supreme Court on Tuesday held in Coney Island Auto Parts Unlimited, Inc. v. Burton that litigants do not have unlimited time to challenge judgments as void. Rather, Federal Rule of Civil Procedure 60(c)(1) places a “reasonable-time limit” on such motions, wrote Justice Samuel Alito in the majority opinion.

The dispute arose after a company called Vista-Pro Automotive, LLC, began bankruptcy proceedings in Tennessee more than a decade ago. As part of the proceedings, Vista-Pro’s creditors filed separate lawsuits against companies with unpaid invoices. When one of those companies, Coney Island Auto Parts Unlimited, failed to respond, the creditors succeeded in securing a default judgment against Coney Island from a Tennessee bankruptcy court in 2015.

Soon after the court issued this ruling, Jeanne Burton was appointed as trustee for Vista-Pro. As part of her work, she repeatedly contacted Coney Island about what it owed, and she had the Tennessee bankruptcy court’s judgment registered in New York.

In October 2021, Coney Island asked a New York bankruptcy court to vacate the judgment from Tennessee. Specifically, it contended that the judgment was void because the original complaint from Vista-Pro’s creditors had been served improperly. When the New York court and a U.S. district court declined to intervene, Coney Island in July 2022 filed a motion in Tennessee to vacate the judgment under Rule 60(b)(4), which authorizes courts to invalidate judgments that are void.

The Tennessee bankruptcy court denied the motion based on a past ruling of the U.S. Court of Appeals for the 6th Circuit, holding that a “motion under Rule 60(b) must be made within a reasonable time.” A district court and the 6th Circuit later upheld that decision.

The Supreme Court case centered on the time that passed between when Coney Island was notified of the Tennessee bankruptcy court’s default judgment and when the company filed a motion in Tennessee to have that judgment vacated as void. The justices considered a disagreement between the federal courts of appeals over whether such motions must satisfy the “reasonable time” standard in Rule 60(c)(1) or if, instead, they can be filed at any time.

The court affirmed the 6th Circuit’s ruling against Coney Island, holding that the reasonable-time standard applies. Like oral argument, which lasted less than 40 minutes, the majority opinion was brief, coming in at just six pages.

Writing for the court, Alito explained that the text of Rule 60(c)(1) is clear, stating “that a ‘motion under Rule 60(b) must be made within a reasonable time.’” “Because a motion for relief from an allegedly void judgment is a ‘motion under Rule 60(b),’” he wrote, “the reasonable-time limit applies.”

Alito noted that several courts of appeals have drawn a different conclusion, determining that there is no time limit for motions alleging voidness. But they did so, Alito added, while acknowledging that such a conclusion “clashes with Rule 60’s text.”

The court will not depart from the text to take that step, Alito wrote, in part because Coney Island has not shown that “some principle of law, such as the Due Process Clause,” requires such a departure. “Giving a party a ‘reasonable’ time to seek relief from an allegedly void judgment may well be all that due process demands,” he continued. And to conclude otherwise “would have extreme implications,” such as not requiring a party “to comply with the deadline for filing a petition for a writ of certiorari” under certain circumstances.

Alito concluded by noting that “Coney Island does not contend that it complied with” the reasonable-time standard. “Therefore,” he wrote, “we need not expound on whether Coney Island’s timing was reasonable.”

Justice Sonia Sotomayor agreed with the result that the majority reached, but not its reasoning. In her two-paragraph opinion concurring in the judgment, she wrote that “the majority unnecessarily opines on the potential validity of a constitutional challenge to the ‘reasonable time’ limit under the Due Process Clause.” Such a reflection was not called for, Sotomayor explained, because “Coney Island did not make this argument below and the Sixth Circuit did not pass upon it.”