The question
Whether Federal Rule of Civil Procedure 60(c)(1)'s requirement that a Rule 60(b) motion be made within a reasonable time applies to a motion seeking relief from an allegedly void judgment under Rule 60(b)(4).
Coney Island Auto Parts Unlimited, Inc. v. Burton
What the Court decided
Affirmed. The Court held that 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) states that a motion under Rule 60(b) must be made within a reasonable time, and a voidness motion is a motion under Rule 60(b). Rule 60's structure confirms this reading because the Rule sets no unlimited-time principle for voidness motions, and the reasonable-time standard itself accommodates a defendant who learns of the judgment late.
How the justices split
UnanimousThe Court's opinion
Alito, joined by Roberts, Thomas, Kagan, Gorsuch, Kavanaugh, Barrett, Jackson
The reasonable-time limit in Rule 60(c)(1) applies to a Rule 60(b)(4) voidness motion because such a motion is a motion under Rule 60(b) and the Rule's text and structure impose no unlimited-time exception for voidness. That a void judgment is a legal nullity does not remove the time limit, because most legal errors are also uncurable by time yet remain subject to filing limits, and Coney Island identified no legal principle, such as the Due Process Clause, permitting a voidness allegation at any time. Allowing voidness claims at any time would let parties ignore appeal and certiorari deadlines when jurisdiction is contested, and the reasonable-time standard already accommodates a defendant who learns of a default judgment only upon enforcement.
Concurring in the judgment
Sotomayor, writing alone
Sotomayor agreed with the judgment. The syllabus does not state the reasoning of her separate opinion concurring in the judgment.
How we know · 5 sourced claims
The Court held that Rule 60(c)(1)'s reasonable-time limit applies to a motion alleging a judgment is void under Rule 60(b)(4).
Source: syllabus, Held
Because a motion for relief from an allegedly void judgment is a motion under Rule 60(b), the plain text of Rule 60(c)(1) subjects it to the reasonable-time limit.
Source: syllabus, Held
The Court reasoned that allowing parties to allege voidness at any time would permit ignoring deadlines for notices of appeal or petitions for certiorari when subject-matter jurisdiction is contested.
Source: syllabus, Held
Alito delivered the opinion of the Court, joined by Roberts, Thomas, Kagan, Gorsuch, Kavanaugh, Barrett, and Jackson.
Source: syllabus, lineup
Sotomayor filed an opinion concurring in the judgment.
Source: syllabus, lineup