Cited by

Under the Hughes three- element test, “[a] judgment or order is void if the court entering it lacked jurisdiction: (1) over the subject matter, (2) over the person involved, or (3) to render the particular judgment or order entered.” ¶ 16 (App. 1998) (

¶11 “A judgment or order is ‘void’ if the court entering it lacked jurisdiction: (1) over the subject matter, (2) over the person involved, or (3) to render the particular judgment or order entered.” ¶ 12 (App. 2013) ().

Indeed, “the court must vacate a void judgment or order even if the party seeking relief delayed unreasonably.” (internal quotation marks and citation omitted).

See Brevetti, 1 CA-CV 21-0569 FC, at *3, ¶ 20; (explaining that a judgment or order is “void” if the court entering it “lacked jurisdiction: (1) over the subject matter, (2) over the person involved, or (3) to render the particular judgment or order entered”).

Ruffino, 245 Ariz. at 169, ¶ 10; (explaining there is no time limit for bringing a motion to set aside a void judgment).

If a judgment is void, “the trial court has no discretion but to vacate it.”

(“A judgment or order is ‘void’ if the court entering it lacked jurisdiction.”).

ime limit on Rule 60(b)(4) motions based on improper service of process because a judgment is void if entered without jurisdiction, “even if the party seeking 3 JAMES M. v. SILVIA M., et al. Decision of the Court relief delayed unreasonably.” Ruffino, 245 Ariz. at 168-169, ¶ 10 ().

¶25 Rule 60(b)(4) allows a party to seek relief from a “void” final judgment or order when “the court entering it lacked jurisdiction (1) over the subject matter, (2) over the person involved, or (3) to render the particular judgment or judgment entered.”

¶ 8 (App. 2012); (“A judgment .

Indeed, a judgment entered without jurisdiction because of a lack of proper service is void, Koven v. Saberdyne Sys., Inc., (), and may be challenged via Arizona Rule of Civil Procedure 60(b)(4) at any time, “even if the party seeking relief delayed unreasonably,” (quoting Brooks v. Consol.

" Martin v. Martin , , 14, , 14 (App. 1994) (quoting Brooks v. Consol.

Then, 1 For this proposition, P.2d 11 (App. 1994), a civil child support case, which is inapplicable and adds a quote found nowhere in the opinion.

a party cannot cure a judgment that is so defective as to be void; laches cannot infuse the judgment with life.”) (quoting 7 Moore’s Federal Practice § 60.25(4) (2d ed. 1955)) (emphasis added); Master Fin., ¶ 19 (App. 2004) (motion to vacate void judgment is never untimely, “even in the case of unreasonable delay by the party seeking relief”); (holding that time does not limit court’s duty to vacate a void judgment even when the party seeking relief delayed unreasonably).

P. 60(c); (“A motion for relief brought pursuant to Rule 60(c)(6) must be filed within a reasonable time.”) (internal quotation marks omitted).

–15, 16, –15, 16 (App. 1994); ¶ 8