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

This case asked whether Rule 60(c)(1) limits when someone can challenge a void default judgment (automatic win). The Court held that even these Rule 60(b)(4) motions must be filed within a reasonable time. It unanimously affirmed the Sixth Circuit in a 9-0 opinion by Justice Alito.

Result

Affirmed

Businesses and other defendants facing default judgments are directly affected. A void judgment (legally invalid) still must be challenged within a reasonable time. For example, Coney Island moved after a marshal seized bank funds to satisfy the default judgment. This gives trustees and other judgment holders more finality, while leaving some flexibility for late notice. Lower courts will likely keep deciding what counts as a reasonable time in default-judgment disputes.

Not official Court text.