The question of whether there is a time limit on vacating a void judgment due to lack of personal jurisdiction is set to be deliberated by the Supreme Court on Nov. 4 in the case Coney Island Auto Parts Unlimited Inc. v. Burton. This case highlights a split among federal courts of appeals regarding the interpretation of Federal Rule of Civil Procedure 60(c)(1), which mandates that motions under Rule 60(b) be filed “within a reasonable time.” The specific focus is on judgments deemed void, which Federal Rule 60(b)(4) authorizes courts to vacate.
The case’s origins trace back to a decade-old Tennessee bankruptcy proceeding against Coney Island Auto Parts Unlimited involving Vista-Pro Automotive LLC. Despite Coney Island failing to respond to the complaint and the subsequent default judgment obtained by Vista-Pro in 2015, its validity is now being questioned due to alleged improper service.
In their brief, Coney Island challenges the application of a timeliness restriction by the 6th Circuit, arguing that a judgment deemed void should be a “legal nullity” regardless of when a motion to vacate is filed. Conversely, the respondent, Jeanne Burton, stresses that the plain text of Rule 60, along with related legal precedents, suggests that even void judgments require timely motions to sustain legal certainty and prevent “unfair gamesmanship” in bankruptcy proceedings.
The petition filed by Coney Island underscores how other appellate circuits have classified the timeliness requirement as inapplicable in the case of void judgments, accentuating the case’s significance for future jurisprudence in this area. The 6th Circuit decision maintained by the Tennessee bankruptcy court’s ruling reflects one perspective in this notable judicial debate.
The legal community awaits the Supreme Court’s decision, anticipated by early July, on this contentious and legally nuanced issue, as detailed on SCOTUSblog. The court’s ruling will likely offer a definitive stance on the application of time constraints to void judgments across jurisdictions.