On January 20, 2026, the United States Supreme Court issued its unanimous 9-0 opinion written by Justice Alito with a concurrence by Justice Sotomayor in Coney Island Auto Parts Unlimited, Inc. v. Burton and addressed whether vacating a void judgment has a time limit. Prior to the decision, there was an 11-1 circuit split, and the majority view had been that parties were permitted to move to vacate void judgments irrespective of how much time had passed.
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