Coney Island Auto Parts Unlimited, Inc. v. Burton

Case background

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 the mail-service requirements of Federal Rule of Bankruptcy Procedure 7004(b)(3). Coney Island did not file an answer, and the Bankruptcy Court entered a default judgment in 2015. Over the next six years, Vista-Pro’s bankruptcy trustee attempted to enforce the judgment, sending a demand letter to Coney Island’s CEO in April 2016; those efforts bore fruit in 2021 when a marshal seized funds from Coney Island’s bank account in satisfaction of the judgment. Coney Island then filed a motion to vacate the judgment under Federal Rule of Civil Procedure 60, arguing that Vista-Pro’s failure to make proper service rendered the judgment void. The Bankruptcy Court denied relief, holding that Coney Island had failed to abide by Rule 60’s requirement that parties make motions for relief within a “reasonable time.” The District Court and the Court of Appeals for the Sixth Circuit affirmed.

Questions Presented

(1) Whether Federal Rule of Civil Procedure 60(c)(1) imposes any time limit to set aside a void default judgment for lack of personal jurisdiction.

Holding

Rule 60(c)(1)’s reasonable-time limit applies to a motion alleging that a judgment is void under Rule 60(b)(4). The plain text of Rule 60(c)(1) provides that a “motion under Rule 60(b) must be made within a reasonable time,” and a motion for relief from an allegedly void judgment is such a motion. The structure of the Rule confirms that reading: Rule 60 modifies the default reasonable-time limit expressly when it means to — imposing a 1-year limit on motions alleging mistakes, new evidence, or fraud — yet it includes no analogous unlimited-time principle for motions alleging voidness. That a void judgment is a legal nullity does not change the analysis, because the passage of time cures few legal errors and statutes and rules routinely limit the time for seeking relief from an erroneous judgment. A party would need to identify some principle of law, such as the Due Process Clause, conferring a right to allege voidness at any time, and Coney Island disclaimed any such argument. Neither historical practice nor Insurance Corp. of Ireland v. Compagnie des Bauxites de Guinee supports an unlimited window, and policy concerns, drafting history, and constitutional avoidance carry weight only when a Rule’s language is ambiguous.

The Court

Justice Alito delivered the opinion of the Court, in which Chief Justice Roberts and Justices Thomas, Kagan, Gorsuch, Kavanaugh, Barrett, and Jackson joined. Justice Sotomayor filed an opinion concurring in the judgment, agreeing that Rule 60’s text and structure require the result but objecting that the majority unnecessarily opined on the potential validity of a Due Process Clause challenge to the reasonable-time limit — an argument Coney Island did not raise below and expressly disclaimed in this Court.

What this episode contains

This episode is an AI-narrated reading of the majority opinion in Coney Island Auto Parts Unlimited, Inc. v. Burton, written by Justice Alito.

AI disclosure: The voice in this episode is AI-generated, using a machine learning model styled to loosely resemble the authoring justice. Tone, inflection, pacing, and emphasis are artifacts of the model and should not be attributed to Justice Alito. The text being read is the Court’s published majority opinion, lightly adapted to improve readability for the spoken format.