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Coney Island Auto Parts Unlimited Inc v Burton

Fox Rothschild LLP

Supreme Court Puts a Clock on Attacking “Void” Judgments

Fox Rothschild LLP on

The U.S. Supreme Court has clarified that there is a time limit—specifically, a “reasonable time” under Rule 60(c)(1)—for filing motions to set aside judgments as “void” under Rule 60(b)(4), even where the alleged voidness...more

Freeman Mathis & Gary

Rule 60(b)(4): Not a Get-Out-of-Time-Free card. Supreme Court closes the door on “void anytime” motions.

Freeman Mathis & Gary on

In Coney Island Auto Parts Unlimited, Inc. v. Burton (Chapter 7 Trustee for Vista-Pro Automotive, LLC), the Supreme Court addressed whether Rule 60(c)(1)’s “reasonable time” requirement applies to a motion seeking to set...more

Thompson Coburn LLP

Supreme Court Clarifies Time Limits for Challenging “Void” Judgments Under Rule 60(b)(4)

Thompson Coburn LLP on

The Supreme Court’s recent decision in Coney Island Auto Parts Unlimited, Inc. v. Burton (1/20/26) resolved a decades-long split among circuit courts over whether motions to vacate allegedly void judgments are subject to time...more

Krieg DeVault

Time Limit for Vacating Void Judgments?

Krieg DeVault on

On January 20, 2026, the United States Supreme Court issued its unanimous 9-0 opinion written by Justice Alito with a concurrence by Justice Sotomayor in Coney Island Auto Parts Unlimited, Inc. v. Burton and addressed whether...more

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