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The United States Supreme Court unanimously ruled that federal courts must enforce a time limitation when parties seek to challenge judgments as void under the Federal Rules of Civil Procedure, resolving a deep and persistent split among lower courts. In Coney Island Auto Parts Unlimited Inc. v. Burton, the justices affirmed the 2024 decision of the U.S. Court of Appeals for the Sixth Circuit, holding that Federal Rule of Civil Procedure 60(c)(1) requires that motions to vacate judgments — even those alleged to be void — must be filed within a “reasonable time.” The decision brings clarity to an issue that had divided federal appellate courts for years: whether a litigant may attack a judgment as void at any point in the future, or whether such challenges remain subject to procedural time constraints. By endorsing the Sixth Circuit’s interpretation, the Court reinforced the principle that procedural rules governing finality apply uniformly, even in cases involving alleged jurisdictional defects. The ruling signals the Court’s continued emphasis on textual interpretation of procedural rules and underscores the judiciary’s interest in preserving stability and predictability in civil litigation nationwide.

The dispute arose from a default judgment entered in 2015 against Coney Island Auto Parts, a Brooklyn-area business that later argued it had never been properly served with process. After years passed, the company sought relief from the judgment, contending that improper service rendered the ruling void from the outset. Both the bankruptcy court and the federal district court rejected the motion as untimely, and the Sixth Circuit affirmed. The company urged the Supreme Court to adopt the view held by several other circuits — that a void judgment is a legal nullity and therefore may be challenged at any time. That argument rested on longstanding doctrinal language suggesting that a court lacking jurisdiction produces no valid judgment at all. However, lower courts had struggled to reconcile that concept with the plain language of Rule 60(c)(1), which states that a motion under Rule 60(b) “must be made within a reasonable time.” The Sixth Circuit concluded that the rule’s text contains no exception for void judgments, and the Supreme Court agreed, resolving years of inconsistent interpretations across jurisdictions.