The U.S. Supreme Court unanimously held that challenges to void judgments must be filed within a reasonable time. In Coney Island Auto Parts Unlimited, Inc. v. Burton, the court rejected arguments for unlimited challenge periods. The ruling emphasizes the legal system's need for finality.
In 2014, Vista-Pro filed for bankruptcy and claimed Coney Island Auto Parts Unlimited, Inc. owed it money. A bankruptcy trustee mailed a lawsuit notice to the company but did not address it to an officer or authorized agent, as required by federal rules. Coney Island did not respond, leading to a $50,000 default judgment in 2015 against it for failing to appear properly notified, the company later argued. Letters sent in 2016 to the company's CEO informed it of the judgment, but no action was taken. The trustee sought to collect over the next years. In 2021, after a U.S. marshal seized funds from Coney Island's bank account, the company moved to vacate the judgment as void under Federal Rule of Civil Procedure 60(b)(4), claiming improper service made it a legal nullity with no time limit for challenge. Rule 60(c)(1) requires such motions within a reasonable time. Justice Samuel Alito, writing for the unanimous court on Monday, explained that the reasonable time requirement applies even to void judgments to preserve finality and prevent disruptions to legal deadlines. The court noted the company's awareness since 2016 made its five-year delay unreasonable. > The Court rejects the argument that because a ‘void judgment is a legal nullity,’ no time limit should apply. > A party would need to show that some principle of law, such as the Due Process Clause, gives a party the right to allege voidness at any time. But Coney Island disclaims any such argument, and the Court cannot divine any such principle. Alito wrote. The decision underscores that parties cannot indefinitely delay challenges to potentially flawed judgments.
