Coney Island Auto Parts Unlimited, Inc. v. Burton
View Official PDFBelow are plain-language sections to help you understand what the Court decided in Coney Island Auto Parts Unlimited, Inc. v. Burton and why it matters. Quotes are taken from the syllabus (the Court’s short summary at the start of the opinion).
Summary
A short, plain-English overview of Coney Island Auto Parts Unlimited, Inc. v. Burton.
The Supreme Court addressed whether the reasonable-time requirement under Federal Rule of Civil Procedure 60(c)(1) applies to motions alleging a void judgment under Rule 60(b)(4). Coney Island Auto Parts Unlimited, Inc. argued that improper service rendered a judgment void, but the Court affirmed lower courts' decisions that the reasonable-time limit applies. The Court found no legal principle allowing voidness claims at any time, emphasizing the rule's text and structure.
Holding
The single most important “bottom line” of what the Court decided in Coney Island Auto Parts Unlimited, Inc. v. Burton.
The Court held that Rule 60(c)(1)'s reasonable-time limit applies to a motion alleging that a judgment is void under Rule 60(b)(4).
Constitutional Concepts
These are the Constitution-related themes that appear in Coney Island Auto Parts Unlimited, Inc. v. Burton. Click a concept to see other cases that involve the same idea.
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Why Procedural Due Process is relevant to Coney Island Auto Parts Unlimited, Inc. v. Burton
The case involves the application of procedural rules regarding the timeliness of motions to vacate judgments, which relates to the fairness of legal procedures.
Syllabus excerpt (verbatim)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, but Coney Island disclaims any such argument, and the Court cannot divine any such principle.
Key Quotes
Short excerpts from the syllabus in Coney Island Auto Parts Unlimited, Inc. v. Burton that support the summary and concepts above.
Rule 60(c)(1)’s reasonable-time limit applies to a motion alleging that a judgment is void under Rule 60(b)(4).
The structure of Rule 60 confirms the plain-text interpretation.
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.
