A bankruptcy trustee mailed a lawsuit to Coney Island Auto Parts but failed to address the documents to an officer or authorized agent, as required by federal rules. The company never responded, and a $50,000 default judgment was entered.
But how long can you wait before telling the court it messed up?
On Monday, in Coney Island Auto Parts Unlimited, Inc. v. Burton, the U.S. Supreme Court unanimously ruled that you can’t wait forever. Even if a court’s decision was technically invalid from the start, a challenge must still be filed within a “reasonable time.”
The case began in 2014, when a company called Vista-Pro went bankrupt and claimed that Coney Island Auto Parts owed it money. They sent a legal notice by mail, but the address did not comply with the required rules.
When Coney Island Auto Parts failed to respond (they claimed they weren’t properly notified), a court entered a “default judgment” against the company in 2015.
For the next six years, the bankruptcy trustee attempted to collect the money. In 2016, letters were sent to Coney Island Auto Parts’ CEO informing the company about the judgment, but the company still did nothing.
It wasn’t until 2021, when a U.S. marshal seized funds from the company’s bank account, that Coney Island Auto Parts went to court, arguing the original judgment was “void” because the legal notice had been improperly addressed.
The dispute centered on Federal Rule of Civil Procedure 60:
- Rule 60(b)(4) says a court can cancel a “void” judgment.
- Rule 60(c)(1) says motions to cancel judgments must be made within a “reasonable time.”
Coney Island Auto Parts argued that since a void judgment is a ‘legal nullity’ — and therefore should be treated as if it never existed — there should be no deadline to challenge it.
The Supreme Court disagreed.
Writing for the unanimous Court, Justice Samuel Alito explained that Rule 60 applies a reasonable time requirement to all motions seeking relief from judgments, including claims that a ruling was void.
Allowing parties to challenge judgments decades later, the Court said, would undermine the legal system’s need for finality.
The justices also noted that Coney Island Auto Parts was aware of the judgment in 2016 but waited until 2021 to challenge it.
That delay, the Court said, was unreasonable.
“The Court rejects the argument that because a ‘void judgment is a legal nullity,’ no time limit should apply,” Alito wrote.
He warned that allowing voidness challenges at any time could disrupt core legal deadlines.
“A party would need to show that some principle of law, such as the Due Process Clause, gives a party the right to allege voidness at any time,” Alito wrote. “But Coney Island disclaims any such argument, and the Court cannot divine any such principle.”
This ruling is a warning to U.S. citizens: Don’t ignore legal mail. If you find out a court has ruled against you — even if you think the court made a huge mistake or didn’t have the authority to sue you — you have to act fast. If you wait until the police show up to take your property or freeze your bank account, the Supreme Court says you might be too late.
You can’t “wait and see” with the law. If you know there’s a legal problem, the clock is already ticking.
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