Rule 60(b)(4) After Coney Island: Void Judgments and the Reasonable-Time Requirement
Accuracy update — reviewed August 7, 2026. This article has been revised to reflect Coney Island Auto Parts Unlimited, Inc. v. Burton, 607 U.S. 155 (2026), which resolved a circuit split and held that Federal Rule of Civil Procedure 60(c)(1)’s “reasonable time” requirement applies to Rule 60(b)(4) motions. What Rule 60(b)(4) actually does Federal Rule […]