Coney Island Auto Parts Unlimited, Inc. v. Burton
- Docket Number
- 24-808
- Citation
- 607/1
- Term
- October Term 2025
- Argued
- November 4, 2025
- Decided
- January 20, 2026
- Lower Court
- United States Court of Appeals for the Sixth Circuit
- Author
- Associate Justice Samuel A. Alito, Jr.
- Concurring
- John G. Roberts, Jr., Clarence Thomas, Samuel A. Alito, Jr., Elena Kagan, Neil M. Gorsuch, Brett M. Kavanaugh, Amy Coney Barrett, Ketanji Brown Jackson, Sonia Sotomayor
Read the official slip opinion (PDF)
AI-Generated Summary
1. Case Information:
- Case Name: Coney Island Auto Parts Unlimited, Inc. v. Jeanne Ann Burton, Chapter 7 Trustee for Vista-Pro Automotive, LLC
- Docket Number: 24–808
- Dates: Argued November 4, 2025—Decided January 20, 2026
- Lower Court: United States Court of Appeals for the Sixth Circuit
2. Facts of the Case:
- Vista-Pro Automotive, LLC, entered bankruptcy in 2014 and initiated adversary proceedings against Coney Island Auto Parts Unlimited, Inc., to recover $50,000 in allegedly unpaid invoices. Vista-Pro attempted service by mail but allegedly failed to comply with Federal Rule of Bankruptcy Procedure 7004(b)(3).
- Coney Island did not answer, leading to a default judgment by the Bankruptcy Court in 2015. The bankruptcy trustee pursued enforcement for six years, including sending a demand letter to Coney Island's CEO in April 2016 (deemed notice by lower courts). In 2021, a marshal seized funds from Coney Island's bank account.
- Coney Island then moved under Federal Rule of Civil Procedure 60(b)(4) to vacate the judgment as void due to improper service.
- Procedural History: Bankruptcy Court denied the motion, finding it untimely under Rule 60(c)(1)'s "reasonable time" requirement. The District Court and Sixth Circuit affirmed (109 F. 4th 438). The Supreme Court granted certiorari to resolve a circuit split.
3. Legal Issues Presented:
- Whether Federal Rule of Civil Procedure 60(c)(1)'s "reasonable time" limit applies to motions under Rule 60(b)(4) seeking relief from an allegedly void judgment.
- The case involves interpretation of the Federal Rules of Civil Procedure (applicable to bankruptcy via Rules 7055 and 9024).
- Main Arguments: Petitioner (Coney Island) argued no time limit applies because a void judgment is a "legal nullity," citing history, policy, and cases like United Student Aid Funds, Inc. v. Espinosa. Respondent (Trustee) emphasized the plain text of Rule 60(c)(1) requiring all Rule 60(b) motions within a reasonable time.
4. The Court's Decision (Main Opinion):
- Author & Type: Alito, J., delivered the opinion of the Court (majority opinion, joined by Roberts, C.J., and Thomas, Kagan, Gorsuch, Kavanaugh, Barrett, and Jackson, JJ.).
- Holding: Rule 60(c)(1)'s reasonable-time limit applies to Rule 60(b)(4) motions alleging a void judgment.
- Legal Reasoning:
- Plain text of Rule 60(c)(1) mandates that all "motion[s] under Rule 60(b)" be made "within a reasonable time"; structure confirms this, as the Rule expressly imposes shorter limits (e.g., one year) for other grounds but none for voidness.
- Rejects "legal nullity" argument: Time limits routinely apply to uncorrectable errors; no constitutional or other principle (e.g., Due Process) mandates unlimited challenges to voidness, as that would undermine appellate deadlines.
- Rule accommodates delayed notice (e.g., via enforcement) by using "reasonable time" rather than a fixed limit.
- No historical consensus for unlimited relief; Rule text prevails over history (Honeycutt v. United States); distinguishes Insurance Corp. of Ireland v. Compagnie des Bauxites de Guinee; policy, drafting history, and constitutional avoidance inapplicable absent ambiguity.
- Disposition: Affirmed (Sixth Circuit judgment upheld; no need to assess petitioner's timing).
5. Concurring Opinion(s):
- Sotomayor, J., concurring in the judgment (sole concurrence).
- Agrees Rule 60's text and structure require a "reasonable time" limit for Rule 60(b)(4) motions.
- Criticizes majority for addressing unraised due-process issues, as petitioner disclaimed any constitutional challenge below and here (Burwell v. Hobby Lobby Stores, Inc.); urges adherence to practice of not entertaining unpreserved arguments.
6. Dissenting Opinion(s):
- None.
7. Potential Significance:
- Resolves circuit split on Rule 60(b)(4) timing (e.g., Sixth Circuit vs. First, Third, Fifth, etc.), prioritizing Rule 60's text and structure to promote judgment finality while allowing "reasonable" post-judgment challenges.
- Reinforces that voidness claims (e.g., defective service, jurisdiction) are not exempt from procedural limits, potentially barring stale collateral attacks and encouraging diligence upon notice of enforcement.
This summary was generated by AI and may contain inaccuracies. Refer to the official source document for the authoritative text.
Key terms: Default Judgment, Void Judgment, Reasonable Time Limit