Coney Island Auto Parts, Inc. v. Burton: Oral Argument

Case Summary:Coney Island Auto Parts, Inc. v. Burton arises from a 2015 adversary proceeding in the Vista-Pro Automotive bankruptcy, where Vista-Pro (a Tennessee auto-parts manufacturer) sued Coney Island Auto Parts Unlimited, Inc., a New York corporation, in the Tennessee bankruptcy court to recover approximately $49,000 in unpaid invoices. Vista‑Pro served the summons and complaint by first‑class mail addressed only to “Coney Island Auto Parts Unltd., Inc.” at its Brooklyn business address, without naming or directing service to any officer or registered agent, Coney Island never appeared, and the bankruptcy court entered a default judgment in May 2015, which Vista‑Pro’s Chapter 7 trustee, Jeanne Burton, then spent years trying to enforce, sending a demand letter to Coney Island’s CEO, serving subpoenas, registering the judgment in New York, and ultimately freezing about $97,000 in Coney Island’s bank account, before Coney Island moved in 2021 under Civil Rule 60(b)(4) to vacate the judgment as void for lack of personal jurisdiction. The issue before the Supreme Court was whether a party can seek relief from a void federal judgment under Federal Rule of Civil Procedure 60(b)(4) at any time, or whether such a motion is subject to a time limitm such as Rule 60(c)(1)’s “reasonable time” requirement or equitable doctrines like laches, when the defect is lack of personal jurisdiction based on improper service of process.