Supreme Court Closes a Loophole: Time Limits Now Apply to Void Judgment Challenges
By Mighty Mike Reid
SCOTUS ruled 8-1 in Coney Island Auto Parts v. Burton — time limits now apply to void judgment challenges. Bulletproof documentation matters more than ever.
By Michael Reid, Lead Editor at Process Server Daily / CEO of 123 Legal Inc.
March 19, 2026
The U.S. Supreme Court handed down a unanimous 8-1 decision in Coney Island Auto Parts v. Burton that every process server in the collections space needs to understand. The ruling resolved an 11-1 circuit split and changes the calculus around service documentation permanently.
The Question the Court Answered
Can a defendant attack a default judgment as void — due to defective service of process — at any time, with no time limit? Eleven circuits had said yes. The Supreme Court now says no.
Vista-Pro Automotive failed to follow service requirements when suing Coney Island Auto Parts during 2014 bankruptcy proceedings. More than six years later — when a marshal seized bank funds — Coney Island moved to vacate the judgment as void.
The Ruling
The Court held that all Rule 60(b) motions — including void-judgment challenges — must be brought within a reasonable time under Rule 60(c)(1). SCOTUSblog covered the ruling, and Thompson Coburn published a thorough practitioner analysis.
Why This Matters to You
The ruling gives collection agencies more confidence that default judgments cannot be attacked indefinitely. And it raises the stakes for doing service properly, because defendants who act promptly still have a window to challenge void service.
Bulletproof documentation from every attempt is your professional obligation and your legal protection. GPS-stamped photos, timestamped affidavits, body camera footage — the tools covered in Monday's article — protect your work from post-judgment challenges.
If you are running operations through the Mighty Dashboard at MightyProcessServer.com, your affidavit editor and GPS documentation are already building the proof package this ruling makes essential.
Stay sharp. Stay informed. Live Mighty!
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