Key Takeaway

On January 20, 2026, the Supreme Court held in Coney Island Auto Parts Unlimited, Inc. v. Burton that motions to vacate void judgments under Rule 60(b)(4) must be filed within a “reasonable time.” The longstanding assumption in most circuits—that void judgments could be challenged without any time limit—is gone. Corporate defendants should act promptly upon learning of any judgment entered against them.

Rule 60: The Escape Hatch from Final Judgments

Federal Rule of Civil Procedure 60 provides the primary mechanism for parties to seek relief from final judgments, orders, or proceedings. The rule balances fairness against finality. Rule 60(b) lists six grounds on which a court may reopen a judgment: (1) mistake, inadvertence, surprise, or excusable neglect; (2) newly discovered evidence; (3) fraud or misconduct by an opposing party; (4) a void judgment; (5) a judgment that has been satisfied or is based on a prior judgment that has been reversed; and (6) any other reason justifying relief. But Rule 60(c)(1) imposes time constraints. All Rule 60(b) motions must be made within a “reasonable time,” and motions under subsections (1), (2), and (3) face an additional hard cap of one year.

Rule 60(b)(4) frequently arises in the default-judgment context. When a defendant is never properly served, it may have no idea that litigation has occurred or that a judgment has been entered against it. Rule 55(c), which governs motions to set aside default judgments, expressly directs parties to Rule 60(b) as the vehicle for relief once a default has been entered. This makes Rule 60(b)(4) the principal tool for a defendant seeking to undo a default judgment that it contends is void—typically because of defective service of process or lack of personal jurisdiction.

Before the Supreme Court’s recent decision, the prevailing view in most federal circuits was that Rule 60(c)(1)’s “reasonable time” limit did not apply to Rule 60(b)(4) motions. Because void judgments are “legal nullities,” the conventional reasoning went, a party could challenge a void judgment whenever it chose.

Case Background

The Coney Island Auto Parts case presented a textbook scenario for this question. Vista-Pro Automotive, an auto-parts company in bankruptcy, filed adversarial proceedings against Coney Island Auto Parts Unlimited, Inc. to recover $50,000 in allegedly unpaid invoices. Vista-Pro attempted to serve Coney Island by mail but, according to Coney Island, failed to comply with the requirements for proper service of process. Coney Island never answered, so the Bankruptcy Court entered a default judgment in 2015.

Over the next six years, Vista-Pro’s bankruptcy trustee worked to enforce the judgment, including sending a demand letter to Coney Island’s CEO in 2016. Those efforts culminated in 2021, when marshals seized funds from Coney Island’s bank account. Only then did Coney Island file a motion to vacate the judgment as void under Rule 60(b)(4). The Bankruptcy Court denied relief, holding that Coney Island had not acted within a “reasonable time.” The District Court and the Sixth Circuit affirmed, deepening a split with circuits that had allowed void-judgment challenges at any time.

The Supreme Court’s Holding

In an 8-1 decision by Justice Alito, the Court affirmed. The text of Rule 60(c)(1) expressly imposes the “reasonable time” requirement on all motions filed under Rule 60(b). The Court rejected the argument embraced by the majority of circuits—and by the leading Wright & Miller treatise—that void judgments are “legal nullities” necessarily exempt from time constraints. The passage of time cannot cure voidness, the Court acknowledged, but the same is true of most legal errors—and rules routinely impose deadlines for seeking relief from those. Neither the text of the Rule nor constitutional principles of due process require courts to entertain voidness challenges indefinitely.[1]

At the same time, the Court offered some comfort to defendants blindsided by defective service. The Court emphasized that “reasonable time” is a flexible standard: a defendant who does not learn of a judgment until a plaintiff begins enforcement may well have acted reasonably by waiting until that point to respond. But flexibility is not an open invitation to delay. Once a defendant has notice, the window to act under Rule 60(b)(4) begins to narrow, and at some point it closes. The Court left open several important questions, including the precise contours of “reasonable time” in specific factual settings and whether alternative avenues for relief under Rule 60(d) carry different constraints.

What This Means for Corporate Defendants

The practical impact of Coney Island Auto Parts is straightforward: the era of indefinite challenges to void judgments is over. Companies with operations across multiple jurisdictions, subsidiaries, or trade names are most exposed because service defects are more likely to go unnoticed—and an unnoticed default judgment is now harder to undo. The decision also affects companies that know about claims filed where they are not subject to personal jurisdiction and plan to challenge the resulting judgment through a collateral attack. In either scenario, once a defendant becomes aware of a judgment it believes is void, the clock is running. A defendant that first learns of a void judgment through enforcement efforts can likely challenge it at that point. But the longer the defendant waits after gaining that knowledge, the greater the risk that Rule 60(b) relief is no longer available.

[1] Justice Sotomayor concurred in judgment only, explaining she would decide the case purely on the text of Rule 60 without commenting on any constitutional due-process implications.