Facts of the Case

Provided by Oyez

In November 2014, Vista-Pro Automotive, LLC, a Nashville-based auto-parts corporation, entered bankruptcy proceedings in the U.S. Bankruptcy Court for the Middle District of Tennessee. In 2015, Vista-Pro—later represented by its Chapter 7 trustee—filed an adversary proceeding against Coney Island Auto Parts Unlimited, Inc., a New York corporation, to recover about $50,000 in unpaid invoices. Vista-Pro mailed the summons and complaint to Coney Island’s Brooklyn address addressed only to the corporate entity, not to any officer, agent, or individual as required for proper service under the rules governing service on corporations. Coney Island did not respond to the complaint, leading the bankruptcy court in May 2015 to enter a default judgment against it.

Following reconversion of the case to a Chapter 7 proceeding, the trustee repeatedly attempted to collect the judgment. Coney Island received notice of the judgment at least as early as April 2016 when its CEO was sent a demand letter. Years later, after the trustee sought to enforce the judgment by freezing Coney Island’s bank assets in New York, Coney Island sought to vacate the default judgment, arguing that it was void due to improper service and lack of personal jurisdiction.

The bankruptcy court and later the district court denied Coney Island’s motion to vacate the judgment as untimely. The U.S. Court of Appeals for the Sixth Circuit affirmed, holding that under its precedents interpreting Federal Rule of Civil Procedure 60(c)(1), motions to vacate void judgments must be filed within a reasonable time.

Questions

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

Conclusions

  1. A motion to set aside a judgment as void under Federal Rule of Civil Procedure 60(b)(4) must be filed within a "reasonable time" as required by Rule 60(c)(1). Justice Samuel Alito authored the majority opinion of the Court.

    The text and structure of Federal Rule of Civil Procedure 60 compel this conclusion. The rule’s plain language in subdivision (c)(1) states that “a motion under Rule 60(b) must be made within a reasonable time.” Because a motion challenging a judgment as void is made under subdivision (b)(4), it is a “motion under Rule 60(b)” and is therefore subject to the reasonable-time requirement. The rule’s structure reinforces this interpretation. For certain other motions under Rule 60(b)—those alleging mistake, new evidence, or fraud—the rule expressly creates an exception to the “reasonable time” standard by imposing a fixed one-year deadline. The absence of a similar provision creating an unlimited time frame for voidness motions shows that no such special exception exists.

    The argument that a “void judgment is a legal nullity” and thus cannot be subject to a time limit is unpersuasive. While the passage of time may not cure a judgment’s voidness, the law routinely places time limits on a party's ability to seek relief from judgments containing other types of legal errors. Allowing a party to challenge a judgment as void at any time would have extreme consequences, undermining the finality of judgments and conflicting with established deadlines for appeals. Furthermore, the “reasonable time” requirement is flexible and accommodates situations where a party does not receive proper notice of a lawsuit. In the case of a default judgment, for example, it may be entirely reasonable for a defendant to wait to file a motion for relief until after learning of attempts to enforce the judgment.

    Justice Sonia Sotomayor authored an opinion concurring in the judgment, agreeing that the rule’s text required the outcome but arguing that the majority should not have addressed potential constitutional issues that the parties had not raised.