Date: Feb 22, 2026

Rule 60(b)(4) Motions Must Be Filed Within a Reasonable Time Even When the Underlying Judgment Is Alleged Void

Introduction

In Maria Navarro Martin v. State of Florida, the Eleventh Circuit reviewed a pro se Florida prisoner’s attempt to set aside a federal habeas dismissal order via Federal Rule of Civil Procedure 60(b)(4), which permits relief from a “void” judgment. The procedural history mattered more than the merits of any habeas claim.

The petitioner, Maria Navarro Martin, initially filed a federal habeas petition under 28 U.S.C. § 2241 challenging her Florida witness-tampering conviction and sentence. The district court dismissed the petition without prejudice, explaining that a state prisoner attacking a state conviction must proceed under 28 U.S.C. § 2254. About fifteen months later, Navarro Martin moved under Rule 60(b)(4) to vacate the dismissal, arguing the judgment was void due to lack of personal jurisdiction and due process deficiencies—principally tied to her not receiving the dismissal order when it issued. The district court denied the motion, and the Eleventh Circuit affirmed.

The key issue on appeal was narrow: whether the district court correctly denied Rule 60(b)(4) relief on timeliness and, secondarily, on the absence of jurisdictional or due-process defects that could render the judgment “void.”

Summary of the Opinion

The Eleventh Circuit affirmed the denial of Navarro Martin’s Rule 60(b)(4) motion. The court held that:

A Rule 60(b)(4) motion must be filed within a reasonable time under Rule 60(c)(1), even when the movant claims the underlying judgment is void.
Navarro Martin’s filing—approximately 15 months after the habeas dismissal—was untimely; and even if she did not receive the dismissal order initially, she had notice by June 2023 yet waited about six additional months.
Because the motion was not filed within a reasonable time, the district court properly denied it (and the Eleventh Circuit did not need to reach an extended merits discussion of “voidness”).

Analysis

Precedents Cited

Bainbridge v. Gov. of Fla., 75 F.4th 1326 (11th Cir. 2023)

Bainbridge v. Gov. of Fla. supplied the Eleventh Circuit’s framework for Rule 60(b)(4) “voidness” and the standard of review. The opinion reiterated two critical limits:

A judgment is void only for a certain type of jurisdictional error or a due process violation that deprives a party of notice or an opportunity to be heard.
A judgment is not void merely because it is “or may have been erroneous.”

Bainbridge thus narrows Rule 60(b)(4) to exceptional defects rather than ordinary legal mistakes—an important backdrop to the court’s refusal to treat alleged errors in handling a habeas filing as automatically “voiding” the judgment.

Gonzales v. Crosby, 545 U.S. 524 (2005)

The court cited Gonzales v. Crosby for the baseline proposition that the movant bears the burden to show entitlement to Rule 60(b) relief. While Gonzales is also famous for distinguishing true Rule 60(b) motions from disguised successive habeas petitions, here it functioned primarily as a burden-of-proof anchor: Navarro Martin had to demonstrate both procedural propriety (including timeliness) and substantive “voidness.”

Coney Island Auto Parts Unlimited, Inc. v. Burton, No. 24-808, 607 U.S. , 2026 WL 135998 (Jan. 20, 2026)

The opinion relied heavily on Coney Island Auto Parts Unlimited, Inc. v. Burton for a clear, contemporary rule: litigants seeking relief under Rule 60(b)(4) must comply with Rule 60(c)(1) and file within a reasonable time. This matters because some litigants historically argued that “void judgments” may be attacked at any time. The Eleventh Circuit treated Coney Island as foreclosing that notion and confirming that “voidness” does not eliminate the timeliness requirement.

United Student Aid Funds, Inc. v. Espinosa, 559 U.S. 260 (2010)

United Student Aid Funds, Inc. v. Espinosa was cited to define what “reasonable time” requires in this context: diligence. Espinosa’s “sleep on their rights” language was used as a norm-setting principle: even if a party could articulate a potentially qualifying defect, delay can forfeit Rule 60(b)(4) relief when the litigant fails to act promptly after learning of the judgment.

Stansell v. Revolutionary Armed Forces of Colom., 771 F.3d 713 (11th Cir. 2014)

Stansell v. Revolutionary Armed Forces of Colom. reinforced the timeliness/diligence point through circuit-level application: denial of Rule 60(b)(4) was affirmed where the movant “sat on his rights” by waiting several months. Stansell helps translate the abstract “reasonable time” standard into practical enforcement—delays measured in months, not years, can be fatal. That precedent made Navarro Martin’s additional six-month delay after admitted notice (June to December 2023) especially difficult to justify.

Spencer v. Kemna, 523 U.S. 1 (1998)

While not central to the Rule 60(b)(4) holding, Spencer v. Kemna was cited for mootness: claims seeking dismissal of Medicaid fraud charges became moot after the State dropped those charges. This underscores that federal habeas courts will not decide issues lacking a live controversy, and that collateral events can narrow what remains justiciable.

Campbell v. Air Jam. Ltd., 760 F.3d 1165 (11th Cir. 2014) and Timson v. Sampson, 518 F.3d 870 (11th Cir. 2008)

The court cited Campbell v. Air Jam. Ltd. and Timson v. Sampson to emphasize liberal construction of pro se filings. Importantly, the outcome shows the limit of that solicitude: generous reading does not excuse noncompliance with procedural rules like Rule 60(c)(1)’s “reasonable time” requirement.

Navarro Martin v. Florida, No. 23- 12412, 2025 WL 350355 (11th Cir. Jan. 31, 2025) (unpublished)

The panel noted a prior appeal in which it affirmed the denial of Navarro Martin’s request for a certified copy of the record. This citation was primarily contextual, showing the petitioner had continued to litigate issues connected to the dismissed habeas case and reinforcing that she was on notice of the procedural posture well before filing the Rule 60(b)(4) motion.

Legal Reasoning

The court’s reasoning proceeded in a disciplined, gatekeeping sequence typical for Rule 60(b)(4):

Identify the Rule 60(b)(4) standard. The panel reiterated that voidness is limited to specified jurisdictional errors or due process failures depriving notice/opportunity to be heard, and that “erroneous” is not the same as “void” (per Bainbridge v. Gov. of Fla.).
Apply Rule 60(c)(1)’s timeliness requirement. Relying on Coney Island Auto Parts Unlimited, Inc. v. Burton, the court treated “reasonable time” as mandatory even for 60(b)(4) motions.
Measure reasonableness by diligence after notice. The panel credited Navarro Martin’s assertion that she did not receive the September 2022 dismissal order when issued because it was mailed to the wrong facility; however, it found she had actual notice by June 2023, when the district court denied her records request and referenced the dismissal. Under United Student Aid Funds, Inc. v. Espinosa and Stansell v. Revolutionary Armed Forces of Colom., the question became: did she act diligently once she knew?
Conclude the delay was unreasonable. Waiting roughly six months after June 2023 to file the Rule 60(b)(4) motion (and roughly fifteen months from the judgment itself) constituted sleeping on rights, making denial appropriate without needing a more extensive “voidness” analysis.

In effect, the court treated timeliness as a threshold bar: even potentially serious allegations about jurisdiction or notice do not guarantee relief if the litigant does not act promptly upon learning of the judgment.

Impact

Although the decision is labeled “NOT FOR PUBLICATION” and therefore lacks precedential force in the same way as a published Eleventh Circuit opinion, it is still instructive in at least four ways:

Post-Coney Island enforcement of timeliness for “void” judgments. The opinion operationalizes Coney Island Auto Parts Unlimited, Inc. v. Burton by rejecting any suggestion that Rule 60(b)(4) can be brought at leisure. Practitioners should treat “voidness” as narrow and time-sensitive.
Actual notice can start the clock. Even if service/mail delivery fails, later events (orders, docket activity, other litigation steps) can establish notice that triggers a duty to act diligently.
Pro se status does not relax Rule 60(c)(1). Liberal construction of filings does not excuse lengthy delay.
Habeas procedural choices matter. The underlying dismissal—directing a state prisoner challenging a conviction to § 2254 rather than § 2241—signals that litigants should select the correct statutory vehicle, because procedural missteps can consume time and create additional limitations problems (including limitations periods and exhaustion requirements) even when a case is dismissed “without prejudice.”

Complex Concepts Simplified

Rule 60(b)(4) (“void judgment”): A narrow remedy allowing a federal court to set aside a judgment only when the court lacked the kind of jurisdiction needed to act, or when there was a fundamental due process failure (like no notice and no chance to be heard). It is not a redo because the court may have made a legal mistake.
Rule 60(c)(1) (“within a reasonable time”): The timing rule for Rule 60 motions. Even for Rule 60(b)(4), the movant must act reasonably promptly, especially once they learn the judgment exists. Waiting months after actual notice can be deemed unreasonable.
De novo review vs. abuse of discretion: “De novo” means the appellate court decides the legal question fresh (used for whether a judgment is void). “Abuse of discretion” is more deferential (often used for Rule 60 decisions generally). This opinion acknowledged both but resolved the case on timeliness.
Habeas under § 2241 vs. § 2254: Both are federal habeas statutes, but state prisoners challenging a state-court judgment typically must use § 2254, which carries specific requirements (like exhaustion and deference rules). A court may dismiss a misfiled § 2241 petition without prejudice to refiling under § 2254.
Mootness: A federal court won’t decide issues that no longer matter to the parties. When Florida dropped the Medicaid fraud charges, any request to dismiss those charges became moot (as reflected by the citation to Spencer v. Kemna).

Conclusion

The Eleventh Circuit’s decision reinforces a practical, procedural rule with significant consequences: even when a litigant frames a challenge as attacking a “void” judgment under Rule 60(b)(4), the motion must still be filed within a reasonable time, and “reasonable” is measured by diligence after notice. By anchoring its analysis in Coney Island Auto Parts Unlimited, Inc. v. Burton, United Student Aid Funds, Inc. v. Espinosa, and Stansell v. Revolutionary Armed Forces of Colom., the court signaled that delay can independently bar relief—making timeliness a decisive threshold issue in post-judgment litigation, including in the habeas context.