Supreme Court: Reasonable Time Limit Applies to Void Judgment Motions

The Supreme Court held in Coney Island Auto Parts Unlimited, Inc. v. Burton, Chapter 7 Trustee for Vista-Pro Automotive, LLC, that a motion to vacate a judgment as void under Rule 60(b)(4) must still be filed within a "reasonable time" as required by Rule 60(c)(1). The Court rejected the argument that void judgments can be challenged at any time, emphasizing that the plain text and structure of Rule 60 support applying the reasonable time limit to all Rule 60(b) motions, including those alleging voidness. The case involved a default judgment entered in 2014, which the defendant sought to vacate in 2021, arguing improper service of process rendered the judgment void.

This ruling has significant implications for parties seeking to challenge judgments, particularly those based on service defects. Litigants must now demonstrate that their motions to vacate void judgments are filed within a reasonable timeframe, which will be fact-dependent and could preclude challenges raised long after the judgment was entered. Courts will need to assess the reasonableness of the delay in each case. Failure to comply with this requirement could result in the denial of motions to vacate, leaving the original judgment in effect.