No. 24-808October Term 2025Decided Jan 20, 2026Updated Sep 2, 2026
Coney Island Auto Parts Unlimited v. Jeanne Ann Burton, Chapter 7 Trustee for Vista-Pro Automotive
Coney Island Auto Parts Unlimited, Inc., Petitioner v. Jeanne Ann Burton, Chapter 7 Trustee for Vista-Pro Automotive, LLC
The Supreme Court unanimously left the Sixth Circuit's decision in place.
Case status
Decided 9-0 · January 20, 2026 · Opinion by Justice Alito
Read the opinion (PDF)- Current stage
- Decided
- Latest event
- Decision released Jan 20, 2026
- What it's about
The Court unanimously affirmed a Sixth Circuit decision in a 9-0 ruling authored by Justice Alito. The case addressed business law and contractual obligations.
Question presented
Does Federal Rule of Civil Procedure 60(c)(1) impose any time limit to set aside a void default judgment for lack of personal jurisdiction?
- Case path
United States Court of Appeals for the Sixth Circuit / Decision released Jan 20, 2026
- Area
Business and Regulation
Decision
What the Court decided
The Supreme Court unanimously left the Sixth Circuit's decision in place.
- Result
- Affirmed
Impact
People and businesses challenging a default judgment (a judgment entered when no answer is filed) are affected. They must challenge a claimed void judgment (one claimed to have no legal effect) within a reasonable time. For example, Coney Island sought relief after a marshal seized bank funds in 2021. This supports finality of judgments while allowing flexibility when defendants learn of enforcement attempts. Courts will assess whether a Rule 60(b)(4) motion was filed within a reasonable time.
Not official Court text.
Vote
- Vote split
- 9-0
- Majority author
- Samuel A. Alito, Jr.
Opinion documents
Briefing
What it's about
The Court unanimously affirmed the Sixth Circuit in a dispute over whether Rule 60(c)(1)'s “reasonable time” requirement applies when a party seeks to undo a default judgment for lack of personal jurisdiction (a court's authority over a party).
Vote
Impact
The decision affects businesses and other parties seeking to challenge default judgments (judgments entered when a party does not respond) as void because the court lacked authority over them. It confirms the Sixth Circuit's approach in this case.
What's next
The decision has been released. Lower courts and parties will apply the Court's ruling when disputes arise over efforts to undo default judgments for lack of personal jurisdiction.
What did the Supreme Court rule in Coney Island Auto Parts v. Burton?
The Court unanimously affirmed the Sixth Circuit's decision. Justice Alito authored the 9-0 opinion.
Who is affected by the Coney Island Auto Parts decision?
Businesses and other parties challenging default judgments as void for lack of personal jurisdiction may be affected. Federal courts will apply the Court's decision in similar disputes.
What happens next after Coney Island Auto Parts v. Burton?
The decision is already released. Lower courts and affected parties must apply it in future proceedings involving this Rule 60(c)(1) question.
Timing
Decided January 20, 2026
The Court released its decision 77 days after oral argument on November 4, 2025. The median for cases argued in November is 160 days.
Documents
Opinions
Samuel A. Alito, Jr.
Audio
Key filings
Briefs on file: 10View on supremecourt.gov
Activity
Docket activity8
AI analysis generated: Impact Analysis
Sep 2, 2026 | Generated
AI analysis generated: Opinion Summary
Sep 2, 2026 | Generated
AI analysis generated: Case Briefing
Sep 1, 2026 | Generated
Opinion added: opinion
Jan 20, 2026 | Court records
Opinion added: Opinion of the Court - A
Jan 20, 2026 | Court records
Audio Recording added: Oral Arguments - Burton
Nov 4, 2025 | Court records
Brief added: Petition
Nov 25, 2024 | Court records
Brief added: Questions Presented
Court records
Related cases




Grounding
- Grounding
- Primary materials plus reporting.
- Note
- Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.
- Checked
- Sep 1, 2026
- Method
- Methodology
Primary materials11
Supreme Court docket 24-808
docket | Sep 3, 2026
Primary case document
Supreme Court document | Sep 3, 2026
Questions Presented
brief
Opinion
opinion | Jan 20, 2026
Opinion of the Court (Samuel A. Alito, Jr.)
opinion | Jan 20, 2026
Oral argument
audio | Nov 4, 2025
Petition
brief | Nov 25, 2024
SupremeCourt.gov
official | Sep 2, 2026
SupremeCourt.gov
official | Sep 2, 2026
SupremeCourt.gov
official | Sep 2, 2026
SupremeCourt.gov
official | Sep 2, 2026