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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
Docket number: 24-808
Term: 2025
Court: United States Supreme Court
Important dates
Argued: November 4, 2025
Court membership
Chief Justice John Roberts • Clarence Thomas • Samuel Alito • Sonia Sotomayor • Elena Kagan • Neil Gorsuch • Brett Kavanaugh • Amy Coney Barrett • Ketanji Brown Jackson

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

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."[1]
  • The outcome: The appeal is pending adjudication before the U.S. Supreme Court.


    • 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:[2]

    • 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:[3]

    “ 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. [4]

    		”

    To learn more about this case, see the following:

    Timeline

    The following timeline details key events in this case:[5]

    Questions presented

    The petitioner presented the following questions to the court:[1]

    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.[4] ”

    Oral argument

    Audio

    Audio of oral argument:[6]




    Transcript

    Transcript of oral argument:[7]

    Outcome

    The case is pending adjudication before the U.S. Supreme Court.

    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.[8]


    See also

    External links

    Footnotes

    1. ↑ 1.0 1.1 Supreme Court of the United States, "24-808 CONEY ISLAND AUTO PARTS UNLIMITED, INC. V. BURTON QP", June 6, 2025
    2. ↑ Supreme Court of the United States, "No. 24-808 Coney Island Auto Parts Unlimited, Inc. v. Burton," accessed June 16, 2025
    3. ↑ Oyez, "Coney Island Auto Parts Unlimited, Inc. v. Burton," accessed October 30, 2025
    4. ↑ 4.0 4.1 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
    5. ↑ SCOTUSblog, "Coney Island Auto Parts Unlimited, Inc. v. Burton," accessed October 30, 2025
    6. ↑ Supreme Court of the United States, "Oral Argument - Audio," argued November 4, 2025
    7. ↑ Supreme Court of the United States, "Oral Argument - Transcript," argued November 4, 2025
    8. ↑ SupremeCourt.gov, "The Supreme Court at Work: The Term and Caseload," accessed January 24, 2022
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