Supreme Court: Reasonable Time Limit Applies to Void Judgment Motions

1 (Slip Op inion) OCTOBER TERM, 2025 Syllabus NOTE: Where it is feasible, a syllabus (headnote) will be released, as is being done in connection with this case, at the t ime the opin ion is issue d. The syllabus constitutes no par t of the op inion of the Cour t but has been prepared by t he Report er of Decisions for the conve nience of the reader. See United States v. Detr oit Timber & Lumber Co., 200 U. S. 321, 337. SUPREME COURT OF THE UNI TED STATES Syllabus CONEY ISLAND AUTO PARTS UNLIMITED, INC. v. BURTON, CHAPTER 7 TRUSTEE FOR VISTA-P RO AUTOMOTIVE, LLC CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT No. 24–808. Argued November 4, 2025—Decided Januar y 20, 2026 The question in this case is whet her Federal Rule of Civil Procedure 60(c)(1)’s requirement th at parties make Rule 60(b) motions within a “reasonable time” applies to a motion seeking relief from an allegedly void judgment under Rule 60(b)(4). Vista- Pro Automotive, LLC, en- tered bankruptcy in 2014 and initiated adversar ial proceedings against Coney Island Au to Parts Unlimited, Inc., to collec t $50,000 in allegedly unpaid invoices. Vista-Pro attempted to serve process on Co- ney Island by mail but purportedly fa iled to comply with Federal Rule of Bankruptcy Procedure 7004(b)(3)’s mail-serv ice requirements. Co- ney Island did not file an answer, and the Bankruptcy C ourt entered a default judgment. Over the n ext six years, Vista-Pro’s bankru ptcy trustee attempted to enforce the judg ment. These efforts bore fruit in 2021 when a marshal seized fun ds from Coney Island’s bank acc ount in satisfaction of the judgment. Co ney Island filed a motion to vacate the judgment under Federal Rule of Civil Procedure 60, argu ing that Vista-Pro’s failur e to ma ke proper service rendered the judgment void. The Bankruptcy Court denied relief, holding that Coney Island failed to abide by Rule 60’s requiremen t that parties make motions for relief within a “reasonable time.” The Di strict Court and the Court of Ap- peals for the Sixth Circuit a ffirmed. Held: Rule 60(c)(1)’s reasonable-ti me limit applies to a motion alleging that a judgment is void un der Rule 60(b)(4). Pp. 2–6. (a) The plain text of Rule 60(c)(1) provides that a “motion under Rule 60(b) must be made within a reason able time,” and because a motion

2 CONEY ISLAND AUTO PARTS UNLIMITED, INC. v. BURTON Syllabus for relief from an allegedly void judgment is a “motion under Rule 60(b),” the reasonable-time l imit applies. The str ucture of Rule 60 con- firms the plain-text interpretation. Rule 60 expressly modifies the de- fault reasonable-time limit, imposing a one-y ear limit on Rule 60(b) motions alleging mistakes, new evidence, or fraud. Yet the Rule does not include an analogous unlimited-t ime principle for motions alleging voidness. Pp. 2–3. (b) The Court rejects the argument that because a “void judgment is a legal nullity,” United Stud ent Aid Funds, Inc. v. Espinosa, 559 U. S. 260, 270, no time limit shou ld apply. Even if th e passage of time can- not cure voidness, the same principl e holds true for most legal errors, yet statutes and rules routinely lim it the time during which a party can seek relief from a judgm ent infected by error. A party would need to show that some principle of la w, such as the Due Process Clau se, gives a party the right to a llege voidness at any time, but Coney Isla nd disclaims any su ch argument, an d the Court cannot divine any such principle. Allowing parties to allege voidness at any time would have extreme implications, such as allowing parties to ignore deadlines for filing notices of appeal or petition s for certiorari when subject-matter jurisdiction is contested. The possibility that improper service is dif- ferent from other legal error s because a party might not learn about proceedings until long af ter judgment issues does not help Coney Is- land. Rule 60(c)(1) acco mmodates such a scenar io by imposing a rea- sonable-time requirement rather than a fixed time limit. In the con- text of a default judgment, it might be reasonable for a defendant not to seek relief before learnin g about a plaintiff’s attemp ted enforce- ment. Pp. 3–5. (c) The Court rejects Coney Island’s argument that courts ha ve his- torically allowed litigants to seek relief from void judgments at any time. No such historical c onsensus exists, and in any event, for Rule 60(b) motions, the Rule’s text and st ructure take priority over histori- cal practice. The Court also reject s Coney Island’s reliance on Insur- ance Corp. of Ireland v. Compagnie des Ba uxites de Guinee, 456 U. S. 694, as that case under mines Coney Island’s plea for no time limits. Lastly, the Court rejects Coney Island’s invocation of policy concerns, Rule 60’s drafting histor y, and the ca non of constitutional avoidance. To the extent that these interpretive tools carry an y weight, they do so only when a Rule’s language is ambiguous. Pp. 5–6. 109 F. 4th 438, affirmed. A LITO, J., delivered the opinion of the Court, in which R OBERTS, C. J., and T HOMAS, K AGAN, G ORSUCH, K AVANAU GH, B ARRETT, and J ACKSON, JJ., joined. S OTOMAYOR, J., filed an opinion concurring in the judgment.

_________________ _________________ 1 Cite as: 607 U. S. ____ (2026) Opinion of the Court NOTICE: This opinion is s ubject to f ormal revision before publicat ion in the United States R eports. Readers are req uested to notify the Rep orter of Decisions, S upreme Court of the United Sta tes, Washing ton, D. C. 20543, pio@supr emecourt.gov, of any t ypographica l or other f ormal errors. SUPREME COURT OF THE UNI TED STATES No. 24–808 CONEY ISLAND AUTO PARTS UNLIMITED, INC., PETITIONER v. JEANNE ANN BURTON, CHAPTER 7 TRUSTEE FOR VISTA-PRO AUTOMOTIVE, LLC ON WRIT OF CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT [January 20, 2026] J USTICE A LITO delivered the opinion of the Court. A party seeking relief from an allegedly void judgment may file a motion under Federal Rule of Civil Procedure 60(b)(4). Rule 60(c)(1) requires parties to make Rule 60(b) motions within a “reasonable time.” We hold that this time limit applies to a motion alleging that a judgment is void. I Vista-Pro Automotive, LLC, entered bankruptcy in 2014. As part of its bankruptcy litigation, Vista-Pro initiated ad- versarial proceedings against Coney Island Auto Parts Un- limited, Inc., to collect $50,000 in allegedly unpaid invoices. Vista-Pro attempted to serve process on Coney Island by mail, but in doing so, it purp ortedly failed to comply with the mail-service requirements in Federal Rule of Bank- ruptcy Procedure 7004(b)(3). Coney Island did not file an answer in the adversarial proceedings, and the Bankruptcy Court entered a default judgment against the company in 2015. Over the next six years, Vista-Pro’s bankruptcy trustee attempted to enforce

2 CONEY ISLAND AUTO PARTS UNLIMITED, INC. v. BURTON Opinion of the Court that judgment against Coney Island. As part of these ef- forts, the trustee sent a demand letter to the company’s CEO in April 2016. Lower courts concluded that this letter gave Coney Island notice of the judgment and the trustee’s enforcement efforts. These efforts bore fruit in 2021 when a marshal seized funds from Coney Island’s bank account in satisfaction of the judgment. In response, Coney Island filed a motion to vacate the judgment under Federal Rule of Civil Procedure 60. According to Coney Island, Vista-Pro’s failure to make proper service rendered the judgment void. The Bankruptcy Court denied relief. It held that Coney Island failed to abide by Rule 60’s requirement that parties make motions for relief within a “reasonable time.” The District Court and Court of Appeals for the Sixth Circu it affirmed. We granted certiorari to resolve a split of author- ity on whether Rule 60’s reas onable-time limit applies to motions seeking relief from allegedly void judgments. 1 605 U. S. ___ (2025). II Federal Rule of Civil Procedure 60 permits a court to “re- lieve a party ... from a final judgment, order, or proceed- ing,” and subdivision (b)(4) specifically authorizes a court to —————— 1 Compare In re Vista-Pro Automotive, LLC, 109 F. 4th 438, 444 (CA6 2024) (case below), with Austin v. Smith, 312 F. 2d 337, 343 (CADC 1962); V. T. A., Inc. v. Airco, Inc., 597 F. 2d 220, 224, and n. 9 (CA10 1979); Rodd v. Reg ion Constr. Co., 783 F. 2d 89, 91 (CA7 1 986); Hertz Corp. v. Alamo Rent-A-Car, Inc., 16 F. 3d 1126, 1130 (CA11 1994); Sea- Land Serv., Inc. v. Ceramica Europa II, In c., 160 F. 3d 849, 852 (CA1 1998); United States v. One Toshiba Color Television, 213 F. 3d 147, 157– 158 (CA3 2000) (en banc); Jackson v. FIE Corp., 302 F. 3d 515, 523 (C A5 2002).

3 Cite as: 607 U. S. ____ (2026) Opinion of the Court grant relief from a “void” judgment. 2 Parties may seek re- lief under Rule 60 by filing a motion with the court. Rule 60 also imposes a time limit for such motions. Rule 60(c)(1) provides that a “motion under Rule 60(b) must be made within a reasonable time.” Because a motion for relief from an allegedly void judgment is a “motion under Rule 60(b),” the reasonable-time limit applies. Accord, Kemp v. United States, 596 U. S. 528, 533 (2022) (“All [Rule 60(b) motions] must be filed ‘within a reasonable time’ ”). The structure of Rule 60 confirms what the plain text of subdivision (c)(1) provides. When Rule 60 modifies the de- fault reasonable-time limit, it does so expressly. For exam- ple, Rule 60(c)(1) imposes a 1-year limit on Ru le 60(b) mo- tions alleging mistakes, new evidence, or fraud. Thus, one would expect Rule 60 to include an analogous provision if a special, unlimited-time principle applied to motions alleg- ing voidness. Cf. Kemp, 596 U. S., at 534–535. But the Rule does not. Coney Island, several Courts of Appeals, and a promi- nent treatise nonetheless maintain that Rule 60(c)(1)’s reasonable-time limit does not apply to motions alleging voidness. See n. 1, supra; 11 C. Wright, A. Miller, & M. Kane, Federal Practice and Procedure §2862, pp. 431–433 (3d ed. 2012). These authorities acknowledge that their in- terpretation clashes with Rule 60’s text. See, e. g., Sea-Lan d Serv., Inc. v. Ceramica Europa II, Inc., 160 F. 3d 849, 852 (CA1 1998). But relying on the generally accepted maxim that a “void judgment is a legal nullity,” United Student Aid Funds, Inc. v. Espinosa, 559 U. S. 260, 270 (2010), they ar- gue that the passage of time cannot turn such a nullity into an enforceable judgment. See, e. g., Austin v. Smith, 312 F. 2d 337, 343 (CADC 1962). —————— 2 Rule 60 governs motions to set asid e default judgments, Fed. Rule Civ. Proc. 55(c), including those issu ed in bankruptcy proceedings, Fed. Rules Bkrtcy. Proc. 7055 and 9024.

4 CONEY ISLAND AUTO PARTS UNLIMITED, INC. v. BURTON Opinion of the Court This argument cannot bear the weight that Coney Island and others have placed on it. Even if the passage of time cannot cure voidness, the same principle holds true for most legal errors. Nevertheless, statutes and rules routinely limit the time during which a party can seek relief from a judgment infected by error. Th erefore, a party in Coney Is- land’s position 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. Coney Island disclaims any such argument, and we can- not divine any principle requiring courts to keep their doors perpetually open to allegations of voidness. Giving a party a “reasonable” time to seek re lief from an allegedly void judgment may well be all that due process demands. By contrast, the argument that a party may allege voidness at any time, if taken to its logical conclusion, would have ex- treme implications. For example, if a federal district court erroneously concluded that it possessed subject-matter ju- risdiction and proceeded to enter a judgment, the adversely affected party could wait as long as it wanted before filing a notice of appeal. But see Fed. Rule App. Proc. 4(a)(1). Similarly, if a federal court of appeals erroneously asserted subject-matter jurisdiction, the adversely affected party would not be required to comply with the deadline for filing a petition for a writ of certi orari imposed by this Court’s Rule 13. It is hard to accept the proposition that due pro- cess requires such a regime. 3 —————— 3 J USTICE S OTOMAYOR c o n t e n d s t h a t w e s h o u l d a b s t a i n f r o m a d d r e s s i n g any potential d ue-process consideration s. Post, at 1 (opinion concurring in jud gme nt). Although Coney Island disc laims any constitutional arg u- ment, it cites a longstanding consens us of authority holding that a party may allege voidness at any time desp ite the contrary language in Rule 60. And the only possible b asis for su ch a holding is a rule of constitu- tional law that prevents the impositi on of the Rule’s reasonable-time re- quirement.

5 Cite as: 607 U. S. ____ (2026) Opinion of the Court Coney Island maintains that the alleged defect in this case—failure to perform proper service—is different from other legal errors that might render a judgment void. 4 Co- ney Island emphasizes that when a party does not receive proper service, it might not learn about the proceedings un- til long after the judgment issues. But this possibility does not help Coney Island’s position. Rule 60(c)(1) accommo- dates such a scenario by imposing a reasonable-time re- quirement, rather than a fixed time limit. And in the con- text of a default judgment, it might be reasonable for a defendant not to seek relief be fore learning about a plain- tiff ’s attempted enforcement. Coney Island separately contends that courts have his- torically allowed litigants to seek relief from void judgments at any time. But the historical record is not so clear. To be sure, courts have granted relief from void judgments long after their entry, especially when the issuing court lacked jurisdiction over the defendant. See, e. g., Harris v. Harde- man, 14 How. 334, 338, 344–346 (1853) (affirming a lower court order that set aside a judgment 11 years after its is- suance where the plaintiff did not make proper service and the defendant did not appear). But there was no historical consensus that a party could request such relief at any time. Some courts, for instance, concluded that laches or other time limits could bar relief, even when a litigant alleged voidness. E.g., Stocking v. Hanson, 35 Minn. 207, 211–212, 28 N. W. 507, 507–508 (1886); Smith v. Jones, 174 Cal. 513, 515–517, 163 P. 890, 890–892 (1917). In any event, for Rule 60(b) motions, the Rule’s “text and structure” take priority over historical practice. 5 See Honeycutt v. United States, 581 U. S. 443, 453 (2017). —————— 4 We express no view on whether the allegedly defective service in this case would render the judgment void. 5 Rule 60(d) preserves parties’ ability to obtain relief from a judgment in limited ways other than through a Rule 60(b) motion. We express no

6 CONEY ISLAND AUTO PARTS UNLIMITED, INC. v. BURTON Opinion of the Court Coney Island turns next to this Court’s decision in Insur- ance Corp. of Ireland v. Compagnie des Bauxites de Guin ee, 456 U. S. 694 (1982). There, we explained that a defendant seeking to dispute personal jurisdiction is “always free to ignore the judicial proceedings, risk a default judgment, and then challenge that judgment ... in a collateral pro- ceeding.” Id., at 706. Citing this sentence, Coney Island argues that defendants need not comply with time limits when alleging a lack of personal jurisdiction. But Insurance Corp. also recognized that the “expression of legal rights is often subject to certain procedural rules,” and “the failure to enter a timely objection” may result in the loss of a legal right. Id., at 705. Thus, Insurance Corp. undermines Co- ney Island’s plea for no time limits. Coney Island lastly invokes policy concerns, Rule 60’s drafting history, and the canon of constitutional avoidance. To the extent that these interpretive tools carry any weight, they do so only when a Rule’s language is ambiguous. See BP p.l.c. v. Mayor and City Council of Baltimore, 593 U. S. 230, 245 (2021); Milner v. Department of Na vy, 562 U. S. 562, 572 (2011); Van Buren v. United States, 5 93 U. S. 374, 393–394 (2021). Here, the operative language clearly re- quires parties to make Rule 60(b) motions within a reason- able time. III Litigants seeking relief under Rule 60(b)(4) must comply with Rule 60(c)(1) and file a motion within a reasonable time. Coney Island does not contend that it complied with this requirement. Therefore, we need not expound on whether Coney Island’s timing was reasonable. The judg- ment of the United States Court of Appeals for the Sixth Circuit is affirmed. It is so ordered. —————— view regarding the limits applicable to obtaining relief through one of those methods.

_________________ _________________ 1 Cite as: 607 U. S. ____ (2026) S OTOMAYOR, J., concurring in judgment SUPREME COURT OF THE UNI TED STATES No. 24–808 CONEY ISLAND AUTO PARTS UNLIMITED, INC., PETITIONER v. JEANNE ANN BURTON, CHAPTER 7 TRUSTEE FOR VISTA-PRO AUTOMOTIVE, LLC ON WRIT OF CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT [January 20, 2026] J USTICE S OTOMAYOR, concurring in the judgment. The Court today rightly holds that a Rule 60(b)(4) motion to set aside a default judgment that is void for lack of pe r- sonal jurisdiction must be made “within a reasonable time.” Fed. Rule Civ. Proc. 60(c)(1). Rule 60’s text and structure require that conclusion, as the majority explains. I concur in the judgment because the majority unneces- sarily opines on the potential validity of a constitutional challenge to the “reasonable time” limit under the Due Pro- cess Clause. Ante, at 4. Coney Island did not make this argument below and the Sixth Circuit did not pass upon it. See In re Vista-Pro Automotive, L LC, 109 F. 4th 438, 443 (2024) (“Coney Island does not mount a constitutional at- tack on Rule 60”). In this Court, Coney Island expressl y disclaimed any due process argument. See Brief for Peti- tioner 22 (“To be clear, Coney Island does not contend that Rule 60 or Rule 60(c)(1) [is] unconstitutional”). This Court does “not generally entertain arguments that were not raised below and are not advanced in this Court by any party.” Bur well v. Hobby Lobby Stores, Inc., 573 U. S. 682, 721 (2014). There is no reason to depart from that practice absent unusual circumstances, which certainly are not pre- sent here.