Hunton Retail Law Resource

In Coney Island Auto Parts Unlimited, Inc. v. Burton (Jan. 20, 2026), the Supreme Court held that motions to vacate void judgments under Federal Rule of Civil Procedure 60(b)(4) are subject to Rule 60(c)(1)’s requirement that they be filed within a “reasonable time.” This rejects the prior view in many circuits that void judgments could be challenged at any time. For corporate defendants, the decision makes prompt action critical: once a company learns of a default judgment it believes is void due to defective service or lack of personal jurisdiction, delay can forfeit Rule 60(b)(4) relief.

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