Coney Island Auto Parts Unlimited, Inc. v. Burton

The Supreme Court ruled that a motion to cancel a judgment because it is "void" (legally invalid) must be filed within a "reasonable time." The Court found that Federal Rule of Civil Procedure 60(c)(1) applies to these requests, meaning parties cannot wait indefinitely to challenge a court's power. This decision affirmed a lower court ruling against Coney Island Auto Parts, which failed to act quickly enough to challenge a debt.

This ruling means businesses and individuals cannot wait years to challenge a court's decision, even if they claim the court lacked the authority to make it. It provides more certainty for winners of lawsuits, as they do not have to worry about a case being reopened decades later. However, it also places a strict burden on defendants to act as soon as they learn about a judgment against them.

The Court balanced the idea that invalid judgments are legal errors with the need for "finality," which is the principle that legal disputes must eventually end. By requiring a "reasonable time" limit, the Court prevents the extreme consequences that would occur if judgments could be overturned at any time. This fits into a broader trend of the Court strictly following the plain text of federal court rules.

9-0. Majority: Alito, Roberts, Thomas, Sotomayor, Kagan, Gorsuch, Kavanaugh, Barrett, Jackson.

“The rule’s plain language in subdivision (c)(1) states that “a motion under Rule 60(b) must be made within a reasonable time.””

“No dissent”

You must act within a "reasonable time" if you want to overturn a court judgment, even if you believe that judgment is legally void.

Courts will now have to decide on a case-by-case basis what counts as a "reasonable time" to challenge a void judgment. For default judgments (where one side did not show up), judges may be more flexible if the person truly did not know about the lawsuit. This ruling will likely discourage parties from waiting until the last minute to seek legal relief.

The Court explained that while the passage of time does not fix a legal error, the law still sets deadlines for seeking relief from those errors. Allowing challenges at any time would undermine the stability of the court system and conflict with established deadlines for appeals.

The Court noted that the "reasonable time" requirement is flexible and can accommodate situations where a party was unaware of a lawsuit. For example, it might be reasonable for a defendant to wait until they learn about an attempt to collect the money before filing a motion.

Justice Sotomayor agreed with the final result based on the text of the rules but argued the majority should not have discussed constitutional issues. She believed the Court should have avoided addressing potential constitutional problems that the parties did not actually raise in the case.