Coney Island Auto Parts Unlimited, Inc. v. Burton
Lower Court: Unknown • Last updated: January 20, 2026
Plain-Language Summary
The Supreme Court addressed a procedural question in bankruptcy law in Coney Island Auto Parts Unlimited, Inc. v. Burton. The case asked whether Federal Rule of Civil Procedure 60(c)(1)'s requirement that parties make Rule 60(b) motions within a "reasonable time" applies to motions seeking relief from void judgments under Rule 60(b)(4). Vista-Pro Automotive entered bankruptcy in 2014 and sued Coney Island Auto Parts to collect $50,000 in unpaid invoices, but allegedly failed to properly serve process.
Justice Alito authored the opinion addressing whether there is a time limit for challenging judgments entered without proper jurisdiction — a question that affects defendants who may not have learned of a court ruling against them until long after it was entered.
Why This Matters
This ruling affects anyone who discovers a court judgment was entered against them without proper notice or jurisdiction. By clarifying whether time limits apply to challenges of void judgments, the Court's decision has practical implications for businesses and individuals in bankruptcy proceedings and other civil litigation where service of process is disputed.