The U.S. Supreme Court unanimously ruled in Coney Island Auto Parts Unlimited, Inc. v. Burton that federal courts must enforce a time limit when a party seeks to challenge a judgment as void under the Federal Rules of Civil Procedure. Before this decision, lower federal appellate courts were deeply divided about whether judgments that are alleged to be void—meaning legally nonexistent from the start—could be challenged at any time, even decades after they were entered. The Supreme Court’s ruling now makes clear that a party asserting that a judgment is void must still file a motion within a “reasonable time” under Rule 60(c)(1). In doing so, the Court resolved a longstanding and significant split among the federal circuits, bringing uniformity to an area of civil procedure that had lacked clear nationwide direction.

The case’s origins date back to a long‑standing legal dispute involving Coney Island Auto Parts Unlimited, an auto parts supplier based in the Brooklyn area. In 2015, a default judgment was entered against the company in federal court after it allegedly failed to respond properly to a lawsuit in which it was a defendant. Years later, Coney Island Auto Parts asserted that it had never been properly served with process and therefore that the default judgment was void. The company filed a motion under Rule 60(b)(4) of the Federal Rules of Civil Procedure, which allows a party to seek relief from a judgment that is void. Crucially, the company did not file this motion until many years after the judgment was entered, raising the question of whether Rule 60(c)(1)’s requirement that a motion be filed within a “reasonable time” applies to voidness challenges as well.

Lower courts had reached different conclusions on this precise question. Several federal courts of appeals had held that challenges to void judgments are exempt from Rule 60(c)(1)’s time limitations because a void judgment is treated as a legal nullity that never took effect in the first place. Under that view, a party could challenge a void judgment at any time, even long after final judgment and appellate review. Other circuits, including the U.S. Court of Appeals for the Sixth Circuit, had held that Rule 60(c)(1)’s requirement that a motion be filed within a reasonable time applies even to voidness claims. The Sixth Circuit’s approach emphasized that the plain text of the rule does not carve out an exemption for void judgments. When the Supreme Court agreed to hear the case, it took on a matter of significant procedural importance with implications for countless civil cases across the country.

Writing for the unanimous Court, Justice Samuel Alito made clear that Rule 60(c)(1) governs all motions under Rule 60, including those asserting that a judgment is void. The Court’s interpretation focused on the language of the rule, which states that “any motion under this rule” must be made within a reasonable time when no specific deadline is otherwise provided. Justice Alito explained that the rule’s text does not distinguish between different types of motions under Rule 60, nor does it exclude motions alleging that a judgment is void. Because Rule 60(b)(4) is part of Rule 60 and is governed by the procedural structure of the rule as a whole, a motion asserting “voidness” must still adhere to Rule 60(c)(1)’s reasonable time requirement.

The Court emphasized that finality in litigation is a fundamental principle of the civil justice system. Allowing parties to challenge judgments indefinitely would undermine that finality, potentially exposing final judgments to collateral attack many years after the underlying dispute has long since concluded. The Court acknowledged that judgments that are truly void—such as those entered by a court lacking subject‑matter jurisdiction—are exceedingly rare, but it maintained that even in those circumstances Rule 60(c)(1) still applies. The decision strikes a balance between ensuring that courts have a mechanism to correct genuinely void judgments while also protecting the integrity of final judgments by preventing stale claims that could destabilize settled litigation.

In explaining how the reasonable‑time requirement applies, the Court declined to adopt a rigid deadline but instead instructed that courts must assess the particular circumstances of each case. Factors that may inform what constitutes a reasonable time include the length of delay between the entry of the judgment and the filing of the motion, whether the movant acted promptly once it became aware of the grounds for relief, and whether any prejudice would result from allowing a late challenge. Justice Alito’s opinion underscored that these considerations mirror longstanding equitable principles behind Rule 60 and reflect a practical approach that accounts for fairness to defendants and the public interest in the finality of judgments.

The unanimous decision in Coney Island Auto Parts Unlimited, Inc. v. Burton is expected to have a significant impact on civil litigation in federal courts. By clarifying that challenges to void judgments are subject to reasonable‑time limits, the Court has eliminated a procedural loophole that allowed parties to reopen long‑closed cases without a clear temporal boundary. Trial and appellate courts will now apply the same framework to assess timeliness in all Rule 60 motions, promoting consistency and predictability in civil procedure. Legal scholars and practitioners have noted that the ruling reinforces the Rule‑of‑Civil‑Procedure system’s emphasis on orderly litigation and the practical necessity of preserving the finality of judgments while still providing an avenue to correct rare but true cases of voidness. As the decision is implemented in lower courts, attorneys will need to be vigilant about timing when considering whether to pursue a voidness challenge, recognizing that delay alone can be fatal to such a motion under the newly clarified standard.