Plain-English summary
Says motions to void judgments under Rule 60(b)(4) must be filed within a 'reasonable time'
In Coney Island Auto Parts v. Burton (No. 24-808), the Supreme Court held that Rule 60(c)(1)’s ‘‘reasonable time’’ requirement applies to motions under Rule 60(b)(4) that a judgment is void. The Court affirmed the Sixth Circuit.
Why this matters
The ruling clarifies that even when a plaintiff says a judgment is void for lack of personal jurisdiction—a claim that used to be treated as automatically subject to vacatur—courts can deny relief if the motion is untimely. That limits the ability of parties to reopen old judgments long after litigation has ended and promotes finality in federal litigation.
Who may feel it
- Parties to federal civil and bankruptcy cases seeking to vacate judgments as void
- Judges and litigators managing post-judgment relief and case finality
- Judgment creditors and debtors relying on long-standing judgments for enforcement
Key questions
- Does the Rule 60(c)(1) ‘‘reasonable time’’ requirement apply to motions under Rule 60(b)(4) alleging a judgment is void?
- Can a court deny a Rule 60(b)(4) vacatur motion as untimely even though the judgment is claimed to be void?