Coney Island Auto Parts, Inc. v. Burton
Digest
A company was hit with a default judgment—an automatic loss for not appearing in court. Years later, when a creditor tried to seize its bank account, the company fought back, claiming the original court never had the power to hear the case against them. The Supreme Court is now deciding whether there is any time limit to challenge a judgment that is claimed to be "void" from the start. A federal rule says such challenges must be made within a "reasonable time," but the question is whether that limit applies to a judgment that was arguably a legal nullity from its inception.
During arguments, the company contended that a void judgment is a due process violation that cannot be made valid by the mere passage of time. The creditor countered that the rule’s text is clear: “reasonable time” means there is always a deadline, providing certainty and finality to the legal process. Justices questioned both sides, probing whether an infinite window to challenge judgments would create chaos, and conversely, whether closing that window could force someone to pay a debt from a case they never had a fair chance to fight.
This ruling will determine the shelf life of default judgments. If the Court finds there is no time limit, anyone holding a default judgment could see it erased years or even decades later. If the Court rules that a "reasonable time" limit applies, individuals and businesses will be required to act promptly to object to a court's power, or risk losing their right to challenge it forever.
Key Moments
Aren't there procedural rules that just say you have to make your claim within a certain time, regardless of whether the judgment is actually void or not?
This question cuts to the heart of the case, suggesting a majority of the court may see this as a simple procedural issue. It separates the process for challenging a judgment from the merits of the challenge itself, which is a major hurdle for the petitioner's 'void means void forever' argument.
What about someone in New York who's never been to Montana, gets a judgment from a Montana court, and just ignores it because it's obviously wrong? Shouldn't they get more time to fix it?
This hypothetical shows judicial concern for the unsophisticated person caught in a clear jurisdictional trap. It tests the flexibility of the respondent's 'reasonable time' standard and signals that the Court is looking for a rule that protects fairness, not just efficiency.
What about fraudulent judgments? The rule gives you only one year to challenge those. Why should a void judgment get more time than one obtained by fraud?
This is a classic logical consistency test. By comparing void judgments to fraudulent ones—which have a strict deadline under the same rule—the Chief Justice is questioning why voidness should get special, unlimited treatment. It suggests he's skeptical of creating a carve-out from the rule's time limits.
Your argument rests on a historical 'common law' rule. But what about the fact that many state courts have historically used time limits (laches) in this exact situation?
This directly attacks the historical foundation of the petitioner's case. By pointing out that the supposed 'unbroken rule' was, in fact, quite broken, she casts serious doubt on the idea that there's a deep-rooted tradition of allowing these challenges at any time.
When asked by Justice Sotomayor about the conflicting history, the attorney tried to pivot back to his core due process argument instead of answering directly, prompting her to say, 'You're going around in a circle.'
This moment revealed a significant weakness in the petitioner's case. The inability to directly rebut the historical evidence suggested his argument was more theoretical than grounded in established practice, and the Justice's pointed remark showed the Court noticed the evasion.
When confronted with the fact that nearly all lower courts disagree with her position, she quipped, 'I think just last term you ruled against a case I argued when all the courts had gone our way.'
This was a savvy, self-deprecating moment that subtly reminded the justices that their job is to correct unanimous errors in the lower courts, not simply follow them. It cleverly turned a point of weakness into a reason for the Court to intervene and set a new national standard.
After the petitioner's attorney seemed hesitant to concede a point, Justice Gorsuch jokingly asked, 'How would you have us write it to preserve that option for you?'
This moment of levity revealed the Justice's sharp awareness of the attorney's tactical maneuvering. It highlighted that lawyers argue not just to win the case at hand, but to shape the legal rule for future cases, and the Court is not naive to this strategy.
Arguments
Petitioner
The petitioner argues that a court judgment made without the proper power is not just wrong, it's a complete legal nothing, and you should be able to challenge it at any time. For a court to have power over a person or company, it must have what’s called “personal jurisdiction.” Think of it like this: a court in California can’t legally resolve a dispute between two people in New York who have never had any contact with California. If that California court tried anyway and issued a judgment, that judgment would be “void from the beginning.” The petitioner’s core point is that something that was never legally real in the first place cannot magically become real and enforceable just because a certain amount of time has passed. It was a nullity on day one, and it remains a nullity forever.
The case centers on a specific court rule, Federal Rule of Civil Procedure 60, which says that motions to undo a judgment must be made within a “reasonable time.” The lower courts used this rule to deny Coney Island’s challenge, saying they waited too long. However, the petitioner contends that this “reasonable time” limit was designed for judgments that are merely flawed or incorrect, not for judgments that are fundamentally void. Applying a time limit to a void judgment is illogical; it’s like saying if you don’t point out a counterfeit hundred-dollar bill fast enough, it becomes real money. The petitioner insists that a court’s only job when faced with a void judgment is to recognize its nonexistence, which is a simple act of confirming a legal fact, not a decision that should be blocked by a deadline.
This argument is critical for protecting a fundamental constitutional right: due process. The petitioner explains that if there's a time limit on challenging void judgments, it creates a dangerous situation. It would force people and small businesses to constantly monitor every court in the country and spend money hiring lawyers to fight lawsuits in places where they have no connection, just to avoid having a legally baseless judgment become permanent through a procedural technicality. Their position is that the law should allow a defendant to completely ignore a case from a court that has no power over them, and then, if the plaintiff ever tries to actually seize their bank account or property, the defendant can step in and have the judgment declared void.
Ultimately, the petitioner claims that a void judgment is a special category, separate from all other flawed judgments. While rules about timeliness are important for bringing finality to most legal disputes, they cannot override the constitutional principle that a court without jurisdiction has no power to act. A judgment from such a court isn't just an error to be corrected; it is a legal ghost that never had any authority. Therefore, asking a court to vacate it isn't about reopening a case—it's about wiping a phantom off the books, an action that should never be considered "too late."
Respondent
The respondent argues that you cannot wait forever to challenge a court judgment, even if you believe that judgment is fundamentally flawed or "void." The case centers on Federal Rule of Civil Procedure 60, which is the official instruction manual for how to ask a court to undo a previous decision. Specifically, the rule states that a motion to set aside a void judgment must be filed within a "reasonable time." The respondent’s entire argument hinges on this simple phrase. They contend that "reasonable time" cannot possibly mean "any time" or "unlimited time," because those are the exact opposite of reasonable. If the rule-makers had intended for there to be no deadline at all for this type of challenge, they would have said so explicitly, just as they did for other issues in a different section of the rule.
This isn't just a debate about words; it's about fairness and predictability in the legal system. The respondent points out that allowing someone to challenge a judgment five, ten, or fifty years later creates chaos. People who win lawsuits need to know that the matter is settled. In this specific case, a bankruptcy trustee, who is responsible for gathering assets for people who are owed money, relied on the validity of this judgment. The trustee spent years and thousands of dollars trying to collect the debt from Coney Island Auto Parts. The respondent argues it is fundamentally unfair and unreasonable for Coney Island to sit silently, watch the trustee waste all that time and money, and only then claim the original judgment was void. A "reasonable time" to act would have been when they first learned someone was trying to collect.
The respondent pushes back against the petitioner's core idea that a "void" judgment is a legal nothingness that can be erased at any moment. They argue that the law separates the merits of a claim (whether the judgment is actually void) from the procedure for making that claim. You don't get to ignore the procedural rules just because you think you have a winning argument. You must first follow the rules—in this case, filing your challenge within a reasonable time—to earn the right to make your case. The respondent compares this to other legal principles where, for the sake of finality, even incorrect or void judgments are sometimes left in place if they weren't challenged properly and on time.
Ultimately, the respondent asks the court to apply a flexible, common-sense standard. What counts as a "reasonable time" would depend on the specific facts of each case. A court would consider factors like when the person learned about the judgment, whether they are a sophisticated company or an individual with no legal knowledge, and, most importantly, whether their delay harmed the other party. For an unsophisticated person who ignores a strange legal notice from another state, a long delay might be perfectly reasonable. But for a company like Coney Island that was repeatedly notified that a trustee was trying to collect a debt, waiting over five years was not. The respondent insists that the legal system needs this rule to ensure that disputes eventually come to an end.