Coney Island Auto Parts Unlimited, Inc., Petitioner v. Jeanne Ann Burton, Chapter 7 Trustee for Vista-Pro Automotive, LLC

The case asked whether Federal Rule of Civil Procedure 60(c)(1) sets a time limit for trying to undo a default judgment as void because the court lacked personal jurisdiction. The Supreme Court said that Rule 60(c)(1)'s "reasonable time" requirement does apply and unanimously agreed with the Sixth Circuit.

The Court ruled 9-0 to affirm the Sixth Circuit in an opinion by Justice Alito.

Majority

Alito

Roberts

Thomas

Sotomayor

Kagan

Gorsuch

Kavanaugh

Barrett

Jackson

This means parties cannot wait forever to attack an allegedly void default judgment. Businesses, trustees, and other litigants now have stronger reason to raise personal-jurisdiction objections promptly.

Lower courts must apply the Supreme Court's answer when parties file Rule 60 motions claiming a judgment is void for lack of personal jurisdiction. Litigants and trustees will now have to focus more on whether a challenge was brought within a reasonable time, not just on whether jurisdiction was missing.

The dispute was whether Rule 60(c)(1) limits how long a party can wait before asking a court to erase an allegedly void default judgment. The Court said the rule's reasonable-time limit applies.

Businesses, bankruptcy trustees, and other parties facing old default judgments are directly affected. They cannot assume a personal-jurisdiction challenge can be raised at any time.

Federal trial and appeals courts must follow this rule in future Rule 60 cases. Parties filing these motions will now need to show they acted within a reasonable time.