.svg?rev=a492cc1069df46bdab38f8cb66573f1c&hash=2617C9FE8A7B0BD1C43269B5D5ED9AE2)
The Supreme Court held in Coney Island Auto Parts Unlimited, Inc. v. Burton, No. 24-808, that litigants seeking relief under Rule 60(b)(4) for relief from a purportedly void judgment must comply with Rule 60(c)(1)’s directive that the motion be filed within a reasonable time.
Vista-Pro Automotive, LLC, entered bankruptcy in 2014 and then initiated adversarial proceedings against Coney Island Auto Parts to collect on allegedly unpaid invoices. In serving process on Coney Island, Vista-Pro purportedly failed to comply with the requirements in the Federal Rules of Bankruptcy Procedure. After Coney Island did not answer the adversarial proceedings, the Bankruptcy Court entered a default judgment against it; and then for six years Vista-Pro’s trustee attempted to collect the judgment against Coney Island. In 2021, a marshal seized funds from Coney Island’s bank account in satisfaction of the judgment, which prompted Coney Island to file a motion to vacate the judgment under Federal Rule of Civil Procedure 60, claiming that Vista-Pro’s failure to effect proper service rendered the judgment void.
The Bankruptcy Court denied Coney’s Island’s motion, reasoning that it failed to abide by Rule 60’s requirement that parties make motions for relief within a “reasonable time.” The District Court and Sixth Circuit affirmed. The Supreme Court granted certiorari and likewise affirmed.
The Supreme Court reasoned that Federal Rule of Civil Procedure 60(b)(4) expressly authorizes a court to grant relief from a “void” judgment, and the Rule also imposes a time limit for motions brought pursuant to it. Rule 60(c)(1) provides that motions under Rule 60(b), such as a motion for relief from an allegedly void judgment, must be brought “within a reasonable time.” The Court thus concluded that under a plain reading of the statute, the reasonable time limit applied to motions for relief from an allegedly void judgment.
In so holding, the Court rejected the argument that Rule 60(c)(1)’s reasonable time limit does not apply because a void judgment is a legal nullity, noting that statutes and court rules routinely limit the time during which a party can seek relief from a judgment infected by error. The Court stated it could think of no principle — due process or otherwise — that would require treating void judgments as a legal nullity. The Court further reasoned that considerations of whether, when, and how the objecting party received notice are properly addressed through Rule 60(c)(1)’s reasonableness requirement, rather than through a bright-line rule exempting failure-of-notice claims from the rule.
Finally, it rejected various policy, drafting-history, and avoidance arguments, noting that, to the extent interpretive rules carry any weight, they do so only when a Rule’s language is ambiguous, and Rule 60 is clear.
Justice Alito delivered the opinion of the Court, in which Chief Justice Roberts and Justices Kagan, Gorsuch, Kavanaugh, Barrett, and Jackson joined. Justice Sotomayor filed an opinion concurring in the judgment.
