Coney Island Auto Parts Unlimited, Inc. v. Burton

607 U. S. 155 (2026) · 1/20/26

Federal Rule of Civil Procedure 60(c)(1)’s reasonable-time limit applies to a motion alleging that a judgment is void under Rule 60(b)(4).

The question in this case is whether Federal Rule of Civil Procedure 60(c)(1)'s requirement that 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, entered bankruptcy in 2014 and initiated adversarial proceedings against Coney Island Auto Parts Unlimited, Inc., to collect $50,000 in allegedly unpaid invoices. Vista-Pro attempted to serve process on Coney Island by mail but purportedly failed to comply with Federal Rule of Bankruptcy Procedure 7004(b)(3)'s mail-service…

Held: Rule 60(c)(1)'s reasonable-time limit applies to a motion alleging that a judgment is void under Rule 60(b)(4). Pp. 158–162. (a) The plain text of Rule 60(c)(1) provides that a “motion under Rule 60(b) must be made within a reasonable time,” and because a motion for relief from an allegedly void judgment is a “motion under Rule 60(b),” the reasonable-time limit applies. The structure of Rule 60 confirms the plain-text interpretation. Rule 60 expressly modifes the default reasonable-time limit, imposing a 1-year limit on Rule 60(b) motions alleging mistakes, new evidence, or fraud. Yet…