In a unanimous decision, the U.S. Supreme Court ruled Monday that parties must challenge void judgments within a reasonable time, rejecting the argument that such judgments can be challenged at any point because they are legally null from the start.
The case, Coney Island Auto Parts Unlimited, Inc. v. Burton, arose from a 2014 bankruptcy proceeding in which Vista-Pro claimed Coney Island Auto Parts owed it money. The trustee mailed legal notice to the company but failed to address documents to an officer or authorized agent as required by federal rules.
When Coney Island Auto Parts failed to respond, a default judgment of $50,000 was entered against it in 2015. The company did not challenge the judgment at that time, even after receiving letters in 2016 informing it of the ruling. Only when a U.S. marshal seized funds from the company's bank account in 2021 did Coney Island Auto Parts challenge the judgment as void due to improper notice.
Writing for the unanimous Court, Justice Samuel Alito explained that Federal Rule of Civil Procedure 60 applies a reasonable time requirement to all motions seeking relief from judgments, including claims that a ruling was void. The Court warned that allowing parties to challenge judgments decades later would undermine the legal system's need for finality.
What the Left Is Saying
Progressive advocates and consumer rights groups have raised concerns about the ruling's potential impact on defendants with limited legal resources. The National Consumer Law Center has noted that individuals and small businesses may not have the expertise to recognize when they have been improperly served, and the ruling could disproportionately affect those who cannot afford prompt legal representation.
Some progressive legal scholars argue that the decision places excessive burden on parties to immediately respond to legal notices they may not fully understand. Civil rights organizations have emphasized that due process protections should account for situations where defendants lack awareness of their rights or face barriers to accessing legal assistance.
Additionally, some voices on the left have pointed out that the ruling could be exploited by creditors and trustees who may fail to follow proper notice procedures, knowing that defendants face steep deadlines to challenge judgments. The American Civil Liberties Union has historically emphasized the importance of robust due process protections, and some advocates worry this decision narrows those protections in practice.
What the Right Is Saying
Conservative legal commentators and business groups have largely praised the decision as a necessary clarification that supports the stability of the legal system. The U.S. Chamber of Commerce has stated that clear deadlines for challenging judgments are essential to maintaining the predictability businesses need when operating in the legal system.
Conservative justices and commentators have emphasized that Rule 60's reasonable time requirement serves important purposes beyond the individual case. Allowing parties to challenge void judgments at any time could create decades of uncertainty, potentially disrupting subsequent transactions, other legal proceedings, and the broader reliance interests of parties who believed matters were resolved.
The Federalist Society has noted that the Court's ruling appropriately balances finality with fairness, requiring parties to act promptly while still allowing reasonable time to challenge improper judgments. Conservative legal scholars have also pointed out that the ruling does not eliminate due process protections but rather establishes a reasonable timeframe within which those protections must be asserted.
What the Numbers Show
The case involved a $50,000 default judgment entered in 2015. Coney Island Auto Parts became aware of the judgment in 2016 when letters were sent to its CEO, but did not file a challenge until 2021 — a five-year delay that the Court deemed unreasonable.
Under Federal Rule of Civil Procedure 60(c)(1), motions to cancel judgments must be made within a reasonable time. The Court's decision establishes that even void judgments — those that are invalid from the outset due to lack of jurisdiction or failure to follow proper procedures — must be challenged within a reasonable period.
The ruling applies uniformly to all parties regardless of the underlying basis for claiming a judgment is void. The Court noted that Coney Island Auto Parts was aware of the judgment for five years before challenging it, and this delay alone supported finding the challenge untimely.
The Bottom Line
The Supreme Court's unanimous ruling sends a clear signal: parties who receive adverse judgments must act promptly to challenge them, even if they believe the judgment is void. The decision emphasizes the legal system's interest in finality and prevents parties from waiting until enforcement actions begin to raise procedural objections.
For defendants, the practical implication is that ignorance of a judgment or disagreement with its basis must be asserted within a reasonable time — typically interpreted as months, not years. Waiting until law enforcement takes action to collect on a judgment risks being deemed untimely.
The ruling does not address the underlying question of whether Coney Island Auto Parts was properly notified, focusing instead on the procedural question of timeliness. Future cases may explore what constitutes a reasonable time in various circumstances, particularly where defendants face genuine barriers to understanding their legal rights.