Justices Put Reasonable-Time Limit On Void-Judgment Motions

What happened

The U.S. Supreme Court held Tuesday that parties seeking to set aside allegedly void judgments under Federal Rule of Civil Procedure 60(b)(4) must still move within a reasonable time, affirming a Sixth Circuit ruling against Coney Island Auto Parts Unlimited Inc.

Writing for the Court, Justice Samuel Alito said Rule 60(c)(1) states that Rule 60(b) motions must be made within a reasonable time, and the justices held that “this time limit applies to a motion alleging that a judgment is void.” The ruling resolves a split over whether void-judgment challenges are exempt from Rule 60's timing requirement.

The case arose from Vista-Pro Automotive LLC's bankruptcy litigation to collect $50,000 in allegedly unpaid invoices from Coney Island. Vista-Pro allegedly failed to comply with bankruptcy mail-service rules, Coney Island did not answer, and the Bankruptcy Court entered a default judgment in 2015.

After years of collection efforts, a marshal seized funds from Coney Island's bank account in 2021, prompting the company to move to vacate the judgment under Rule 60 on the theory that defective service made the judgment void. The Bankruptcy Court denied relief as untimely, and the district court and Sixth Circuit affirmed.

The Supreme Court said Rule 60's text and structure defeat the argument that void-judgment motions are exempt from timing limits. The Court noted that Rule 60 expressly creates a one-year limit for certain categories of motions but contains no comparable unlimited-time rule for motions alleging voidness.

The Court also rejected Coney Island's reliance on the maxim that a void judgment is a legal nullity. Even if time cannot cure voidness, Justice Alito wrote, rules and statutes routinely restrict when parties may seek relief from judgments infected by legal error, and the company had not advanced a due process theory requiring courts to keep the door open indefinitely.

The opinion left some issues unresolved. The Court said it expressed no view on whether the allegedly defective service would actually render the judgment void, and it declined to decide whether Coney Island's timing was reasonable because the company did not contend that it had complied with Rule 60(c)(1).

Justice Sonia Sotomayor concurred in the judgment. She agreed that Rule 60's text and structure require a reasonable-time limit, but said the majority unnecessarily discussed a possible due process challenge that Coney Island had disclaimed.