The United States Supreme Court unanimously ruled that federal courts must enforce a time limitation when parties seek to challenge judgments as void under the Federal Rules of Civil Procedure, resolving a deep and persistent split among lower courts. In Coney Island Auto Parts Unlimited Inc. v. Burton, the justices affirmed the 2024 decision of the U.S. Court of Appeals for the Sixth Circuit, holding that Federal Rule of Civil Procedure 60(c)(1) requires that motions to vacate judgments — even those alleged to be void — must be filed within a “reasonable time.” The decision brings clarity to an issue that had divided federal appellate courts for years: whether a litigant may attack a judgment as void at any point in the future, or whether such challenges remain subject to procedural time constraints. By endorsing the Sixth Circuit’s interpretation, the Court reinforced the principle that procedural rules governing finality apply uniformly, even in cases involving alleged jurisdictional defects. The ruling signals the Court’s continued emphasis on textual interpretation of procedural rules and underscores the judiciary’s interest in preserving stability and predictability in civil litigation nationwide.

The dispute arose from a default judgment entered in 2015 against Coney Island Auto Parts, a Brooklyn-area business that later argued it had never been properly served with process. After years passed, the company sought relief from the judgment, contending that improper service rendered the ruling void from the outset. Both the bankruptcy court and the federal district court rejected the motion as untimely, and the Sixth Circuit affirmed. The company urged the Supreme Court to adopt the view held by several other circuits — that a void judgment is a legal nullity and therefore may be challenged at any time. That argument rested on longstanding doctrinal language suggesting that a court lacking jurisdiction produces no valid judgment at all. However, lower courts had struggled to reconcile that concept with the plain language of Rule 60(c)(1), which states that a motion under Rule 60(b) “must be made within a reasonable time.” The Sixth Circuit concluded that the rule’s text contains no exception for void judgments, and the Supreme Court agreed, resolving years of inconsistent interpretations across jurisdictions.

Writing for the Court, Justice Samuel Alito emphasized that the analysis began and ended with the rule’s text and structure. Rule 60(b) identifies several grounds for relief from a final judgment, including subsection (4), which permits relief if “the judgment is void.” Rule 60(c)(1), in turn, sets forth the timing requirement for all motions under Rule 60(b), mandating that they be filed within a reasonable time. According to Justice Alito, nothing in the rule’s language carves out a special exemption for void-judgment claims. The Court reasoned that treating void judgments as categorically exempt would require reading into the rule an exception that its drafters did not include. The opinion further stressed that procedural rules are designed to balance fairness with finality. Even if a litigant raises a serious jurisdictional concern, the orderly administration of justice requires that challenges be brought promptly. By enforcing a reasonableness standard, courts retain flexibility to consider equitable circumstances while preventing indefinite exposure to litigation.

The decision resolves a pronounced circuit split. A majority of federal appellate courts had held that void judgments could be attacked at any time because a legally void order lacks binding force from inception. These courts reasoned that enforcing a time limit would, in effect, breathe life into a nullity. In contrast, a minority of circuits, including the Sixth Circuit, required litigants to act within a reasonable time, emphasizing the rule’s textual clarity and the systemic importance of finality. During oral argument, Justice Ketanji Brown Jackson noted that determining whether a judgment is truly void can itself be complex and contested. The Court’s ruling implicitly acknowledges that complexity: by requiring timely motions, courts can evaluate alleged defects while evidence remains accessible and before reliance interests deepen. The unanimous outcome signals a shared institutional concern among the justices about protecting the integrity of procedural frameworks that govern federal litigation. The ruling ensures uniformity across jurisdictions and provides litigants with clearer expectations regarding post-judgment relief.

In a separate but equally consequential decision, the Supreme Court issued a 6-3 ruling striking down a series of tariffs imposed by former President Donald Trump, concluding that he lacked statutory authority under the International Emergency Economic Powers Act to enact broad trade penalties without explicit congressional authorization. The decision marked a significant judicial check on executive power in the realm of international trade. The tariffs, which targeted goods from numerous U.S. trading partners, had been central to the administration’s strategy to address trade imbalances and bolster domestic manufacturing. Writing for the majority, the Court held that while Congress granted the president authority to regulate certain economic transactions during national emergencies, that delegation did not extend to sweeping tariff regimes absent clear legislative approval. The opinion reaffirmed the constitutional principle that the power to impose tariffs rests primarily with Congress under Article I. By invalidating the measures, the Court underscored the limits of executive authority and emphasized that significant economic policy decisions require unmistakable statutory grounding.

The ruling drew sharp political reactions. Vice President JD Vance criticized the decision on social media, describing it as “lawlessness” and arguing that it would hinder the president’s ability to protect American industries and supply chains. He contended that Congress had provided sufficient authority to regulate imports and suggested that the Court’s interpretation unduly restricted executive flexibility. President Trump likewise criticized the ruling but signaled that his administration would pursue alternative statutory avenues to advance its trade agenda. Legal observers noted that other trade statutes remain available to the executive branch. George Washington University Law School professor Jonathan Turley commented that the administration retains “other tools in its toolbox” to impose tariffs under different legal authorities, suggesting that the dispute over trade powers is far from settled. Together, the Court’s procedural ruling in Coney Island Auto Parts and its tariff decision reflect an ongoing judicial effort to clarify the boundaries of authority — both within the federal court system and between the political branches — reinforcing textual interpretation, institutional limits, and the enduring balance between flexibility and finality in American law.