Vista-Pro Automotive, LLC, entered bankruptcy in 2014 and sued Coney Island Auto Parts Unlimited, Inc., to collect unpaid invoices. Vista-Pro attempted to serve Coney Island by mail but allegedly failed to comply with specific service requirements under the Federal Rules of Bankruptcy Procedure. Coney Island did not answer, and the Bankruptcy Court entered a default judgment in 2015. For six years, the bankruptcy trustee attempted to enforce the judgment, sending a demand letter in 2016 and seizing funds from Coney Island's bank account in 2021. Only after the marshal seized funds did Coney Island file a motion to vacate the judgment, arguing that the defective service rendered the judgment void. The lower courts denied relief, ruling that the motion was filed too late under Rule 60's reasonable-time requirement.
Justice Alito, writing for a unanimous Court, began with the plain text of Rule 60(c)(1), which states that a motion under Rule 60(b) must be made within a reasonable time. The Court reasoned that a motion seeking relief from a void judgment is, by definition, a motion under Rule 60(b), and therefore the time limit applies. The Court looked to the structure of Rule 60, noting that while the Rule expressly modifies the time limit for specific grounds like mistake or fraud to one year, it contains no analogous provision granting an unlimited time for voidness claims. The Court rejected the petitioner's reliance on the maxim that a void judgment is a legal nullity. The opinion explained that even if time cannot cure voidness, statutes and rules routinely limit the time to seek relief from judgments infected by error. The Court noted that allowing parties to allege voidness at any time would have extreme implications, such as allowing parties to ignore deadlines for appeals or certiorari petitions. Furthermore, the Court found that the reasonable-time requirement in Rule 60(c)(1) already accommodates scenarios where a party might not learn of proceedings until later, such as when enforcement efforts occur years after judgment. The Court also dismissed arguments based on historical practice, the Insurance Corp. of Ireland precedent, and policy concerns, concluding that the clear text of the Rule controls.
This decision clarifies that parties cannot wait indefinitely to challenge default judgments based on voidness. Litigants must file motions under Rule 60(b)(4) within a reasonable time, which may be determined by when they learn of the judgment or enforcement efforts. The ruling resolves a split in authority among the Circuit Courts and reinforces the finality of judgments, even those alleged to be void. The case was remanded to the lower courts to apply the reasonable-time standard, though the Court affirmed the judgment because the petitioner did not contend it had complied with the requirement.