Case Preview: Coney Island Auto Parts v. Burton | The Time Trap Tangle: When Void Judgments Gain Validity

Coney Island Auto Parts v. Burton | Case No. 24-808 | Oral Argument Date: 11/5/25 | Docket Link: Here Question Presented: Whether Federal Rule of Civil Procedure 60(c)(1) imposes any time limit to set aside a default judgment void for lack of personal jurisdiction. Overview This episode examines a deceptively simple civil procedure case that could fundamentally reshape how federal courts handle void judgments, creating a constitutional tension between centuries-old legal principles and modern procedural rules about timing requirements for challenging judgments that courts never had authority to enter. Episode Roadmap Opening: The Void Judgment Paradox November 5th, 2025 oral argument date Circuit split: Sixth Circuit stands alone against every other federal circuit Core tension: Can procedural rules validate what should never have existed? Affects every federal court nationwide using Rule 60 Background: The Seven-Year Journey Vista-Pro Automotive bankruptcy in Nashville, Tennessee February 2015: Default judgment against Coney Island Auto Parts for $48,696.21 Coney Island claims never received proper service - no personal jurisdiction 2020: Trustee registers judgment in New York, freezes $100,000 in bank accounts March 2022: Seven years later, Coney Island files Rule 60(b)(4) motion to vacate The Central Legal Question Rule 60(b)(4): Courts can vacate judgments that "are void" Rule 60(c)(1): "Any motion under Rule 60(b) must be made within a reasonable time" Does "reasonable time" apply to truly void judgments? Fundamental question: Can time limits apply to legal nullities? Lower Court Journey Tennessee bankruptcy court grants motion to vacate Sixth Circuit reverses 2-1, applies "reasonable time" requirement Creates circuit split with every other federal circuit Supreme Court grants certiorari to resolve nationwide inconsistency Constitutional Framework: Due Process and Jurisdiction Personal jurisdiction: Court's authority over parties Void judgment: "No judgment at all" - legal nullity from inception Due process concerns: Enforcing judgments without proper notice Historical principle: Void judgments attackable at any time Petitioner's Arguments (Coney Island Auto Parts): Argument 1: Logical Impossibility "If a judgment is void immediately upon entry, how could the passage of time vivify it?" Void means legal nullity - cannot gain validity through delay Procedural rules cannot breathe life into what never existed Argument 2: Historical Practice and Tradition Centuries of precedent allowing challenges to void judgments at any time 1946 Advisory Committee intended "reasonable time" for voidable, not void judgments Advisory Committee statements distinguish void from voidable judgments Argument 3: Judicial Consensus Every circuit except Sixth Circuit recognizes exception for void judgments Well-established understanding that void judgments are special category Circuit split demonstrates widespread acceptance of traditional rule Respondent's Arguments (Burton): Argument 1: Plain Text Controls Rule 60(c)(1): "A motion under Rule 60(b) must be made within a reasonable time" Rule 60(b)(4) is part of Rule 60(b) - text is unambiguous Every tool of statutory interpretation supports time limits Argument 2: Rule Structure and Drafting History Drafters knew how to create exceptions - did so for Rules 60(b)(1)-(3) Advisory Committee rejected proposal imposing no time limits for void judgments Committee agreed "all motions should be made within a reasonable time" Argument 3: Procedural vs. Substantive Distinction Time limits don't validate void judgments - they impose procedural requirements Distinction between judgment validity and challenge procedures Prevents "flagrantly inequitable conduct" and protects finality interests Episode Highlights Key Legal Concepts Explained Personal Jurisdiction: Court's legal authority over parties to a lawsuit Void Judgment: Legal nullity with no validity from the moment entered Default Judgment: Judgment entered when defendant fails to respond Rule 60(b)(4): Federal rule allowing relief from void judgments Service of Process: Legal requirement to provide proper notice of lawsuit Circuit Split: When federal appeals courts reach conflicting decisions Due Process: Constitutional requirement of fair legal proceedings