The lower courts denied the motion, ruling that Coney Island Auto Parts waited too long to file for vacatur under Rule 60(c)(1), which requires motions based on a void judgment to be made within a reasonable time. The courts did not reach the merits of whether the judgment was actually void.
Petitioner’s counsel Daniel Ginzburg argued that judgments void ab initio are nullities from the moment of entry and cannot be validated by the passage of time. He contended that Rule 60(c)(1) cannot apply to such judgments because a void judgment never springs to life, meaning there is no time after which it becomes immune from challenge.
Ginzburg distinguished void judgments from voidable ones, noting that Rule 60(b)(4) covers both. He argued that while voidable judgments carry a reasonable-time limitation, truly void judgments—such as those entered without personal or subject matter jurisdiction—are exempt from such deadlines to satisfy due process requirements.
Respondent’s counsel Lisa S. Blatt argued that the plain text of Rule 60(c)(1) imposes a reasonable-time limit on all motions under Rule 60(b), including those alleging voidness. She emphasized that "reasonable time" does not mean "any time," and pointed to the rule’s history and the Advisory Committee notes as evidence that Congress intended to close off common-law remedies in favor of this structured timeline.
Blatt noted that the three lower courts found Coney Island’s delay unreasonable, with the bankruptcy court observing that the trustee had spent thousands of dollars attempting to enforce the judgment over several years. She argued that allowing indefinite challenges would prejudice judgment creditors who rely on finality and could drain bankruptcy estates.
During oral argument, Justices questioned both sides on the intersection of procedural rules and constitutional due process. Justice Sotomayor pressed Ginzburg on whether the Constitution allows Congress to impose time limits even on void judgments, while Justice Alito challenged Blatt’s position by referencing the Supreme Court’s recent description of void ab initio judgments as if they never existed.
The case presents a fundamental question of federal civil procedure with significant implications for the finality of judgments and the administration of bankruptcy estates.