The United States Supreme Court unanimously ruled that federal courts must enforce a time limitation for parties seeking to challenge judgments as void under the Federal Rules of Civil Procedure. In Coney Island Auto Parts Unlimited Inc. v. Burton, the Court affirmed the Sixth Circuit’s 2024 decision, holding that Federal Rule of Civil Procedure 60(c)(1) requires motions to vacate judgments — even those alleged to be void — to be filed within a “reasonable time.” This ruling resolves a long-standing conflict among federal appellate courts about whether a void judgment can be attacked at any point or remains subject to procedural deadlines, emphasizing the importance of textual interpretation and finality in civil litigation.
The dispute originated from a 2015 default judgment against Coney Island Auto Parts, which claimed it had never been properly served. Years later, the company sought relief, arguing that improper service rendered the judgment void. Lower courts rejected the motion as untimely, and the Sixth Circuit affirmed. Coney Island argued that a void judgment is legally null and should be challengeable at any time. However, the courts emphasized that Rule 60(c)(1)’s language imposes a reasonable time requirement without exceptions for void claims, a position ultimately endorsed by the Supreme Court.
Justice Samuel Alito, writing for the Court, stressed that Rule 60(b) allows relief if a judgment is void but that Rule 60(c)(1) sets the timing for all motions under the rule. The Court found no language exempting void-judgment claims from the time requirement. Alito highlighted that procedural rules balance fairness and finality, ensuring that even serious jurisdictional defects are raised promptly. A reasonableness standard preserves flexibility for equitable circumstances while preventing indefinite litigation and maintaining the orderly administration of justice.
The decision resolves a pronounced circuit split. Most federal appellate courts had allowed void judgments to be attacked at any time, while a minority, including the Sixth Circuit, required timely action. The Supreme Court’s ruling aligns with the latter view, providing uniform guidance for all federal courts. Justice Ketanji Brown Jackson noted during oral arguments that determining whether a judgment is void can be complex, reinforcing the importance of timely motions when evidence and circumstances are still accessible. The ruling provides clarity and predictability for litigants seeking post-judgment relief.
Separately, the Supreme Court issued a 6-3 ruling striking down tariffs imposed by former President Donald Trump, holding that he lacked statutory authority under the International Emergency Economic Powers Act to enact broad trade penalties without explicit congressional approval. The tariffs, aimed at correcting trade imbalances and boosting domestic manufacturing, were deemed beyond the executive’s delegated powers. The Court emphasized that the Constitution vests the power to impose tariffs primarily with Congress, reaffirming limits on unilateral executive authority in economic policy.
The tariff decision sparked political reactions, with Vice President JD Vance and President Trump criticizing the ruling as restrictive to the executive’s ability to protect industries. Legal scholars noted alternative statutory tools remain available for trade regulation, meaning the broader debate over executive authority continues. Together with the procedural ruling in Coney Island Auto Parts, the Supreme Court’s decisions underscore its focus on textual interpretation, institutional limits, and balancing flexibility with finality in both civil procedure and the separation of powers.
