Time limits on void judgments
Coney Island Auto Parts Unlimited v. Jeanne Ann Burton
In brief
The Supreme Court unanimously left the Sixth Circuit's decision in place.
- Where it stands
- Decided
Decided 9-0 · January 20, 2026 · Opinion by Justice Alito
- 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.
- Who it affects
- 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.
Summary: written with AI from the case record.
What it's about
The case addresses how federal procedural deadlines apply to challenges alleging that a court never had authority to enter a judgment.
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?
What the Court decided
The vote
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.
Docket activity
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AI analysis generated: Impact Analysis
AI analysis generated: Opinion Summary
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AI analysis generated: Case Briefing
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Judgment Issued.
Adjudged to be AFFIRMED. Alito, J., delivered the opinion of the Court, in which Roberts, C. J., and Thomas, Kagan, Gorsuch, Kavanaugh, Barrett, and Jackson, JJ., joined. Sotomayor, J., filed an opinion concurring in the judgment.
Opinion added: opinion
Opinion added: Opinion of the Court - A
Audio Recording added: Oral Arguments - Burton
More questions
- 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.
Sources
Primary materials plus reporting. Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.