Where a bankruptcy rule requires commencement of an adversary proceeding before relief can be granted, the failure to commence an adversary proceeding does not deprive the aggrieved party of constitutional due process, so long as the aggrieved party had other, adequate notice of the request for relief.

Where a court commits legal error (here, the failure to make an undue hardship finding as a predicate to a student loan discharge), the erroneous legal result stands if the error is not appealed. The court's order is not "void," but merely erroneous.

Rule 60(b)(4) strikes a balance between the need for finality of judgments and the importance of ensuring that litigants have a full and fair opportunity to litigate a dispute. Where, as here, a party is notified of a plan's contents and fails to object to confirmation of the plan before the time for appeal expires, that party has been afforded a full and fair opportunity to litigate, and the party's failure to avail itself of that opportunity will not justify Rule 60(b)(4) relief.

Prior rulings that hold that a bankruptcy court must confirm a plan containing a legal error so long as the affected creditor does not object are wrong. The bankruptcy court has an obligation to direct a debtor to conform his plan to the requirements of the law.