The Supreme Court’s January 2026 decision in Coney Island Auto Parts Unlimited, Inc. v. Burton, 607 U.S. 155 (2026), resolves a significant circuit split and reinforces a basic principle of judicial efficiency: judgments must eventually become final, even when they suffer from procedural defects. The Court held, without dissent, that Federal Rule of Civil Procedure 60(c)(1)’s requirement that Rule 60(b) motions be filed within a “reasonable time” applies to motions under Rule 60(b)(4) challenging allegedly void judgments. For bankruptcy practitioners, the decision carries substantial weight, particularly those handling adversary proceedings where default judgments and service-of-process disputes are routine.
Background
Vista-Pro Automotive filed Chapter 7 bankruptcy in 2014. Vista-Pro initiated an adversary proceeding against Coney Island Auto Parts Unlimited seeking to recover $50,000 in allegedly unpaid invoices. Service was attempted by mail, and when Coney Island failed to respond, the Bankruptcy Court entered a default judgment in 2015.
The case then lay dormant. Vista-Pro’s bankruptcy trustee attempted to enforce the judgment over the next six years, including by sending a demand letter to Coney Island’s CEO in April 2016 — which lower courts concluded gave Coney Island notice of the judgment and the enforcement efforts. These efforts bore fruit in 2021 when a U.S. marshal seized funds from Coney Island’s bank account to satisfy the judgment. Confronted with asset seizure, Coney Island filed a Rule 60(b)(4) motion arguing the judgment was void because the Bankruptcy Court lacked authority to enter it absent proper service of process. The critical procedural question thus became whether Rule 60(c)(1)’s reasonable-time requirement would bar Coney Island from challenging a judgment entered six years earlier.
The Supreme Court’s Analysis
The circuits had split on this question. Some courts preserved the traditional common law rule that void judgments could be attacked at any time. Others applied Rule 60(c)(1)’s reasonable-time requirement to all Rule 60(b) motions, including void-judgment challenges. The Supreme Court sided with the latter approach, with Justice Alito delivering the opinion for eight Justices and Justice Sotomayor concurring in the judgment.
The majority’s reasoning rested on the text and structure of Rule 60. Rule 60(c)(1)’s text contains no explicit exception for void-judgment motions, and carving out exceptions should not displace the ordinary operation of the Federal Rules. The Court also noted that when Rule 60 modifies the default reasonable-time limit, it does so expressly — for example, by imposing a one-year limit on motions alleging mistakes, new evidence, or fraud — yet includes no analogous unlimited-time provision for motions alleging voidness.
Addressing the longstanding argument that a “void judgment is a legal nullity” and thus immune from time limits, the Court found the argument could not bear the weight placed on it. Even if the passage of time cannot cure voidness, the same principle holds true for most legal errors, yet statutes and rules routinely limit the time during which a party can seek relief from a judgment infected by error. The Court emphasized that judgment finality serves legitimate interests and that a reasonable-time window may well satisfy due process requirements.
The Court further rejected arguments grounded in historical practice, policy concerns, Rule 60’s drafting history, and the canon of constitutional avoidance, finding that the Rule’s text was unambiguous. Notably, the Court also observed that Rule 60(c)(1)’s flexible reasonable-time standard — rather than a fixed deadline — already accommodates the concern that a party who was never properly served might not learn about proceedings until long after judgment issues.
Justice Sotomayor concurred in the judgment but wrote separately to flag that the majority had unnecessarily opined on a constitutional question that no party had raised. While she agreed with the textual holding, she objected to the majority’s discussion of whether due process would be satisfied by a reasonable-time window. Coney Island had expressly disclaimed any constitutional argument, the Sixth Circuit had not addressed one, and in Sotomayor’s view the Court should not have ventured into that territory. Her concurrence was thus a critique of the majority’s judicial restraint, not a substantive disagreement about the due process question itself.
Why This Matters
The decision carries several important implications for bankruptcy practitioners. First, trustees and judgment creditors gain significant protection. Default judgments obtained in adversary proceedings become increasingly difficult to attack after a reasonable period has elapsed, strengthening the hand of trustees seeking to enforce claims and providing greater certainty regarding adversary-proceeding finality.
Second, for practitioners representing defendants in adversary proceedings, the decision underscores the critical importance of prompt responses to complaints. Where service is defective or suspect, the remedy lies in promptly raising jurisdictional objections through responsive pleadings or pre-answer motions, not in waiting years to mount a Rule 60(b)(4) challenge. Delay may result in forfeiture of the right to attack the judgment’s fundamental validity, even where the defendant was unaware of the proceeding due to defective service.
Third, the decision raises strategic questions regarding what constitutes a “reasonable time” in different bankruptcy contexts. The Court did not articulate a bright-line rule; instead it left determination to the lower courts. Bankruptcy practitioners should expect context-specific approaches to defining reasonableness.
Finally, practitioners should recognize how the decision reinforces the importance of proper service of process in adversary proceedings. Service issues must be raised promptly, or the window for relief may close permanently. Coney Island Auto Parts makes clear that compliance is not merely a formality susceptible to collateral attack at any future point.