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Coney Island Auto Parts Unlimited, Inc. v. Burton

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Supreme Court of the United States
Coney Island Auto Parts Unlimited, Inc. v. Burton
Term: 2025
Important Dates
Argued: November 4, 2025
Decided: January 20, 2026
Outcome
affirmed
Vote
9-0
Majority
Chief Justice John Roberts • Clarence Thomas • Samuel Alito • Sonia Sotomayor • Elena Kagan • Neil Gorsuch • Brett Kavanaugh • Amy Coney Barrett • Ketanji Brown Jackson
Concurring
Sonia Sotomayor

Coney Island Auto Parts Unlimited, Inc. v. Burton is a case that was decided by the Supreme Court of the United States on January 20, 2026, during the court's October 2025-2026 term. The case was argued before the Court on November 4, 2025.

In a 9-0 opinion, the Court affirmed the judgment of the United States Court of Appeals for the Sixth Circuit. The Supreme Court held that litigants seeking relief under Rule 60(b)(4) have to comply with Rule 60(c)(1) and file a motion within a reasonable time. Because Coney Island does not argue that it complied with this requirement, the Court concluded that it does not need to discuss whether their timing was reasonable.[1]

HIGHLIGHTS
  • The issue: The case concerns Federal Rule of Civil Procedure 60(c)(1). Click here to learn more about the case's background.
  • The questions presented: "Whether Federal Rule of Civil Procedure 60(c)(1) imposes any time limit to set aside a void default judgment for lack of personal jurisdiction."[2]
  • The outcome: The Supreme Court held that litigants seeking relief under Rule 60(b)(4) have to comply with Rule 60(c)(1) and file a motion within a reasonable time. Because Coney Island does not argue that it complied with this requirement, the Court concluded that it does not need to discuss whether their timing was reasonable.[1]


    • The case came on a writ of certiorari to the United States Court of Appeals for the Sixth Circuit. To review the lower court's opinion, click here.

    Background

    Case summary

    The following are the parties to this case:[3]

    • Petitioner: Coney Island Auto Parts Unlimited, Inc.
      • Legal counsel: Daniel Ginzburg
    • Respondent: Jeanne Ann Burton, Chapter 7 Trustee for Vista-Pro Automotive, LLC
      • Legal counsel: Lisa Schiavo Blatt

    The following summary of the case was published by Oyez, a free law project from Cornell’s Legal Information Institute, Justia, and the Chicago-Kent College of Law:[4]

    “ In November 2014, Vista-Pro Automotive, LLC, a Nashville-based auto-parts corporation, entered bankruptcy proceedings in the U.S. Bankruptcy Court for the Middle District of Tennessee. In 2015, Vista-Pro—later represented by its Chapter 7 trustee—filed an adversary proceeding against Coney Island Auto Parts Unlimited, Inc., a New York corporation, to recover about $50,000 in unpaid invoices. Vista-Pro mailed the summons and complaint to Coney Island’s Brooklyn address addressed only to the corporate entity, not to any officer, agent, or individual as required for proper service under the rules governing service on corporations. Coney Island did not respond to the complaint, leading the bankruptcy court in May 2015 to enter a default judgment against it.

    Following reconversion of the case to a Chapter 7 proceeding, the trustee repeatedly attempted to collect the judgment. Coney Island received notice of the judgment at least as early as April 2016 when its CEO was sent a demand letter. Years later, after the trustee sought to enforce the judgment by freezing Coney Island’s bank assets in New York, Coney Island sought to vacate the default judgment, arguing that it was void due to improper service and lack of personal jurisdiction.

    The bankruptcy court and later the district court denied Coney Island’s motion to vacate the judgment as untimely. The U.S. Court of Appeals for the Sixth Circuit affirmed, holding that under its precedents interpreting Federal Rule of Civil Procedure 60(c)(1), motions to vacate void judgments must be filed within a reasonable time. [5]

    		”

    To learn more about this case, see the following:

    Timeline

    The following timeline details key events in this case:[6]

    Questions presented

    The petitioner presented the following questions to the court:[2]

    Questions presented:
    “ Whether Federal Rule of Civil Procedure 60(c)(1) imposes any time limit to set aside a void default judgment for lack of personal jurisdiction.[5] ”

    Oral argument

    Audio

    Audio of oral argument:[7]




    Transcript

    Transcript of oral argument:[8]

    Outcome

    In a 9-0 opinion, the Court affirmed the judgment of the United States Court of Appeals for the Sixth Circuit. The Supreme Court held that litigants seeking relief under Rule 60(b)(4) have to comply with Rule 60(c)(1) and file a motion within a reasonable time. Because Coney Island does not argue that it complied with this requirement, the Court concluded that it does not need to discuss whether their timing was reasonable.[1] Justice Samuel Alito delivered the opinion of the court.

    Opinion

    In the court's majority opinion, Justice Samuel Alito wrote:[1]

    “

    A party seeking relief from an allegedly void judgment may file a motion under Federal Rule of Civil Procedure 60(b)(4). Rule 60(c)(1) requires parties to make Rule 60(b) motions within a “reasonable time.” We hold that this time limit applies to a motion alleging that a judgment is void.[5]

    		”
    —Justice Samuel Alito

    Concurring opinion

    Justice Sonia Sotomayor filed a concurring opinion.

    In her concurring opinion, Justice Sotomayor wrote:[1]

    “

    I concur in the judgment because the majority unnecessarily opines on the potential validity of a constitutional challenge to the “reasonable time” limit under the Due Process Clause. Ante, at 4. Coney Island did not make this argument below and the Sixth Circuit did not pass upon it. See In re Vista-Pro Automotive, LLC, 109 F. 4th 438, 443 (2024) (“Coney Island does not mount a constitutional attack on Rule 60”). In this Court, Coney Island expressly disclaimed any due process argument. See Brief for Petitioner 22 (“To be clear, Coney Island does not contend that Rule 60 or Rule 60(c)(1) [is] unconstitutional”). This Court does “not generally entertain arguments that were not raised below and are not advanced in this Court by any party.” Burwell v. Hobby Lobby Stores, Inc., 573 U. S. 682, 721 (2014). There is no reason to depart from that practice absent unusual circumstances, which certainly are not present here.[5]

    		”
    —Justice Sonia Sotomayor

    Text of the opinion

    Read the full opinion here.

    October term 2025-2026

    See also: Supreme Court cases, October term 2025-2026

    The Supreme Court began hearing cases for the term on October 6, 2025. The court's yearly term begins on the first Monday in October and lasts until the first Monday in October the following year. The court generally releases the majority of its decisions by mid-June.[9]


    See also

    External links

    Footnotes

    1. ↑ 1.0 1.1 1.2 1.3 1.4 1.5 Supreme Court of the United States, "Coney Island Auto Parts Unlimited, Inc. v. Burto" January 22, 2026
    2. ↑ 2.0 2.1 Supreme Court of the United States, "24-808 CONEY ISLAND AUTO PARTS UNLIMITED, INC. V. BURTON QP", June 6, 2025
    3. ↑ Supreme Court of the United States, "No. 24-808 Coney Island Auto Parts Unlimited, Inc. v. Burton," accessed June 16, 2025
    4. ↑ Oyez, "Coney Island Auto Parts Unlimited, Inc. v. Burton," accessed October 30, 2025
    5. ↑ 5.0 5.1 5.2 5.3 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
    6. ↑ SCOTUSblog, "Coney Island Auto Parts Unlimited, Inc. v. Burton," accessed October 30, 2025
    7. ↑ Supreme Court of the United States, "Oral Argument - Audio," argued November 4, 2025
    8. ↑ Supreme Court of the United States, "Oral Argument - Transcript," argued November 4, 2025
    9. ↑ SupremeCourt.gov, "The Supreme Court at Work: The Term and Caseload," accessed January 24, 2022
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