Flaherty v. Amigos Del Mar LTD.
Split Score
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Case Summary
Disposition
Affirmed
The First Circuit affirmed the district court’s denial of Amigos Del Mar’s Rule 60(b)(4) motion to vacate a $6-million default judgment arising out of a maritime injury, holding that the motion—filed nearly two years after judgment and nineteen months after enforcement efforts—was not made within a reasonable time under Rule 60(c)(1). Relying on the Supreme Court’s recent decision in Coney Island Auto Parts, the panel rejected Amigos’s contention that void-judgment motions are timeless and found no abuse of discretion in deeming the delay unreasonable.
Circuit Split Identified
Legal Issue
Whether Rule 60(c)(1)'s "within a reasonable time" requirement applies to motions brought under Rule 60(b)(4) seeking to declare a judgment void.
Circuit Positions
Rule 60(b)(4) motions are not subject to the "reasonable time" limit of Rule 60(c)(1) and may be filed at any time (pre-Coney Island view).
Rule 60(b)(4) motions must comply with Rule 60(c)(1) and be filed within a reasonable time after the movant becomes aware of the basis for the motion.
Conflict Summary
Until the Supreme Court's 2026 decision in Coney Island Auto Parts v. Burton, the First Circuit treated Rule 60(b)(4) motions as exempt from any time limitation, allowing them to be filed "at any time," whereas the Sixth Circuit (and some others) required compliance with Rule 60(c)(1) and measured reasonableness from when the movant knew or should have known of the basis for the motion.