Coney Island Auto Parts Unlimited, Inc. v. Burton, Chapter 7 Trustee for Vista-Pro Automotive, LLC (24-808)
- Term
- OT 2025
- Argued
- 2025-11-04
- Decided
- 2026-01-20
- Vote
- 9-0 for Burton
- Opinion
- Justice Alito
- Majority
- Roberts, Thomas, Alito, Kagan, Gorsuch, Kavanaugh, Barrett, Jackson
The case in brief
Facts
Vista-Pro Automotive, LLC entered bankruptcy in 2014 and, as part of that case, sued Coney Island Auto Parts Unlimited, Inc. to collect $50,000 in allegedly unpaid invoices. Vista-Pro tried to formally notify Coney Island of the lawsuit by mail, but it allegedly did not follow the required mail-service rules. Coney Island did not respond, so the Bankruptcy Court entered a default judgment (a ruling against a party that fails to answer) in 2015, and after years of collection efforts by Vista-Pro's trustee, a marshal seized money from Coney Island's bank account in 2021. Coney Island then asked the court to cancel the judgment, arguing that the improper service made it void, meaning legally invalid. The Bankruptcy Court refused because Coney Island had not filed within the 'reasonable time' the rule requires, and the District Court and the Sixth Circuit agreed.
Question
Does the rule that requests to undo a court judgment must be filed within a 'reasonable time' also apply when a party claims the judgment is void?
Conclusion
Burton, the trustee, won, as the Court unanimously affirmed the Sixth Circuit, with Justice Alito writing for eight Justices. The Court held that the reasonable-time limit applies to claims that a judgment is void, because the rule's plain words cover every motion of this type and the rule creates no unlimited-time exception for voidness. The Court rejected arguments based on void judgments being legal nullities, on history, and on policy, noting that a flexible 'reasonable time' standard can account for a defendant who learns of a case late. Justice Sotomayor agreed only with the result, writing separately because the majority unnecessarily discussed a due process challenge that Coney Island never raised.
Opinion of the Court
Authored by Justice Alito (2,867 words total).
Volume 607 U. S. Part 1 Pages 155–162
THE SUPREME COURT January 20, 2026
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CONEY ISLAND AUTO PARTS UNLIMITED, INC. v. BURTON, chapter 7 trustee for VISTA-PRO AUTOMOTIVE, LLC certiorari to the united states court of appeals for the sixth circuit No. 24–808. Argued November 4, 2025—Decided January 20, 2026 The question in this case is whether Federal Rule of Civil Procedure 60(c)(1)'s requirement that parties make Rule 60(b) motions within a “reasonable time” applies to a motion seeking relief from an allegedly void judgment under Rule 60(b)(4). Vista-Pro Automotive, LLC, entered bankruptcy in 2014 and initiated adversarial proceedings against Coney Island Auto Parts Unlimited, Inc., to collect $50,000 in allegedly unpaid invoices. Vista-Pro attempted to serve process on Coney Island by mail but purportedly failed to comply with Federal Rule of Bankruptcy Procedure 7004(b)(3)'s mail-service requirements. Coney Island did not fle an answer, and the Bankruptcy Court entered a default judgment. Over the next six years, Vista-Pro's bankruptcy trustee attempted to enforce the judgment. These efforts bore fruit in 2021 when a marshal seized funds from Coney Island's bank account in satisfaction of the judgment. Coney Island fled a motion to vacate the judgment under Federal Rule of Civil Procedure 60, arguing that VistaPro's failure to make proper service rendered the judgment void. The Bankruptcy Court denied relief, holding that Coney Island failed to abide by Rule 60's requirement that parties make motions for relief within a “reasonable time.” The District Court and the Court of Appeals for the Sixth Circuit affrmed.
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Held: Rule 60(c)(1)'s reasonable-time limit applies to a motion alleging that a judgment is void under Rule 60(b)(4). Pp. 158–162. (a) The plain text of Rule 60(c)(1) provides that a “motion under Rule 60(b) must be made within a reasonable time,” and because a motion for relief from an allegedly void judgment is a “motion under Rule 60(b),” the reasonable-time limit applies. The structure of Rule 60 confrms the plain-text interpretation. Rule 60 expressly modifes the default reasonable-time limit, imposing a 1-year limit on Rule 60(b) motions alleging mistakes, new evidence, or fraud. Yet the Rule does not include an analogous unlimited-time principle for motions alleging voidness. P. 158. (b) The Court rejects the argument that because a “void judgment is a legal nullity,” United Student Aid Funds, Inc. v. Espinosa, 559 U. S.
CONEY ISLAND AUTO PARTS UNLIMITED, INC. v. BURTON Syllabus
Excerpt of 8 of 34 paragraphs. Full opinion available on the interactive page or in the official PDF.
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