Coney Island Auto Parts Unlimited, Inc. v. Burton · ¶21

Coney Island separately contends that courts have historically allowed litigants to seek relief from void judgments at any time. But the historical record is not so clear. To be sure, courts have granted relief from void judgments long after their entry, especially when the issuing court lacked jurisdiction over the defendant. See, e. g., Harris v. Harde man, 14 How. 334, 338, 344–346 (1853) (affirming a lower court order that set aside a judgment 11 years after its issuance where the plaintiff did not make proper service and the defendant did not appear). But there was no historical consensus that a party could request such relief at any time. Some courts, for instance, concluded that laches or other time limits could bar relief, even when a litigant alleged voidness. E. g., Stocking v. Hanson, 35 Minn. 207, 211–212, 28 N. W. 507, 507–508 (1886); Smith v. Jones, 174 Cal. 513, 515– 517,…

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