Coney Island Auto Parts Unlimited, Inc.v.Burton
CourtSupreme Court of the United States
Docket No.24-808
Decided2026-01-20
ReporterSlip Opinion, No. 24-808
JudgesSupreme Court of the United States
Tags
Supreme CourtFederal Civil ProcedureRule 60(b)(4)Void JudgmentsTimelinessReasonable Time
Case Summary
A party waited years before moving under Federal Rule of Civil Procedure 60(b)(4) to set aside a judgment as void. The Supreme Court held that Rule 60(c)(1)’s requirement that a Rule 60 motion be made within a reasonable time applies to motions invoking subsection (b)(4). Although a truly void judgment presents exceptional concerns and the permissible time may be generous, the Rules’ text does not exempt voidness motions from the reasonable-time requirement. Courts may consider the nature of the jurisdictional or due-process defect, the movant’s notice, prejudice, and the reason for delay. The judgment was affirmed.
Opinion
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