Coney Island Auto Parts Unlimited, Inc. v. Burton

Questions presented

SCOTUS records, cert granted 6 Jun 2025

Well-settled legal principles dictate that a judgment entered in the absence of personal jurisdiction is void. Federal Rule of Civil Procedure 60(b)(4) authorizes federal courts to vacate a judgment when it is void. A motion seeking vacatur, however, "must be made within a reasonable time." Fed. R. Civ. P. 60(c)(1). Each of the United States Courts of Appeals other than the Sixth Circuit holds that there is effectively no time limit for moving to vacate a judgment, notwithstanding Rule 60(c)(1)'s "reasonable time" requirement, when the judgment is obtained in the absence of personal jurisdiction. The common thinking among these circuits is that a judgment entered without personal jurisdiction is void ab initio. The United States Court of Appeals for the Sixth Circuit is the sole outlier. In this case, it held that Rule 60(c)(1) governs the timing of a motion seeking vacatur of a void judgment pursuant to Rule 60(b)(4). The question presented is: Whether Federal Rule of Civil Procedure 60(c)(1) imposes any time limit to set aside a void default judgment for lack of personal jurisdiction.

Opinion summary

Etalia.ai summary of the majority opinion

The Court held that Rule 60(c)(1)’s requirement that a Rule 60(b) motion be made within a reasonable time applies even when the motion seeks relief under Rule 60(b)(4) on the ground that a judgment is void. Writing for the Court, Justice Alito said the text and structure of Rule 60 control: a motion under Rule 60(b) is subject to Rule 60(c)(1), and the Rule expressly creates special time limits for some grounds but not an unlimited-time exception for void judgments. The Court rejected the argument that void judgments can be challenged at any time because they are legal nullities, explaining that many legal errors are similarly serious but still subject to time limits. It also rejected historical, policy, drafting-history, and constitutional-avoidance arguments. The judgment below was affirmed.