BLOM Bank SAL v. Honickman
605 U. S. ____ (2025) (2025)
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Rule of Law:
Relief under Federal Rule of Civil Procedure 60(b)(6) for vacating a final judgment requires "extraordinary circumstances," and this stringent standard is not lessened when a movant seeks to reopen a case to file an amended complaint, as Rule 60(b) must be satisfied independently before Rule 15(a)'s liberal amendment policy can apply.
Facts:
- Between December 2001 and August 2003, Hamas carried out various terrorist attacks.
- Plaintiffs, who are victims and families of victims of these terrorist attacks, alleged that BLOM Bank SAL aided and abetted these attacks.
- Plaintiffs claimed BLOM Bank SAL provided financial services to customers allegedly affiliated with Hamas, who had helped further Hamas's goals.
- BLOM Bank SAL repeatedly argued to the District Court that the facts alleged in plaintiffs’ complaint were insufficient to state a claim of aiding and abetting.
- Plaintiffs repeatedly affirmed to the District Court that they would stand on their allegations as pleaded and would not seek to amend their complaint if it were dismissed.
Procedural Posture:
- Plaintiffs sued BLOM Bank SAL in the federal District Court under the Anti-Terrorism Act.
- BLOM Bank SAL moved to dismiss the complaint for failure to state a claim under Federal Rule of Civil Procedure 12(b)(6).
- The District Court dismissed the complaint with prejudice, finding plaintiffs had not plausibly alleged the general awareness element for JASTA aiding-and-abetting liability, and denied leave to amend.
- Plaintiffs appealed the dismissal to the Second Circuit Court of Appeals (plaintiffs as appellants, BLOM Bank SAL as appellee).
- The Second Circuit affirmed the dismissal, agreeing the claims failed even though it clarified a less stringent standard for the general awareness element.
- Plaintiffs returned to the District Court and moved under Federal Rule of Civil Procedure 60(b)(6) to vacate the final judgment to file an amended complaint.
- The District Court denied the Rule 60(b)(6) motion, ruling that the Second Circuit's clarification did not constitute "extraordinary circumstances" and that plaintiffs' prior deliberate choices weighed against relief.
- Plaintiffs appealed the denial of their Rule 60(b)(6) motion to the Second Circuit Court of Appeals (plaintiffs as appellants, BLOM Bank SAL as appellee).
- The Second Circuit reversed the District Court's denial, holding that when a party seeks Rule 60(b) relief to file an amended complaint, district courts must balance Rule 60(b)'s finality principles with Rule 15(a)'s liberal amendment policy.
- BLOM Bank SAL sought certiorari from the Supreme Court of the United States.
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Issue:
Does the rigorous "extraordinary circumstances" standard for relief under Federal Rule of Civil Procedure 60(b)(6) apply when a movant seeks to reopen a case to file an amended complaint, or is it tempered by Federal Rule of Civil Procedure 15(a)'s liberal amendment policy?
Opinions:
Majority - Thomas, J.
No, the rigorous "extraordinary circumstances" standard for relief under Federal Rule of Civil Procedure 60(b)(6) does not become less demanding when a movant seeks to reopen a case to amend a complaint. Rule 60(b)(6) is a catchall provision available only in narrow circumstances to prevent it from circumventing the time limitations of other Rule 60(b) paragraphs, and thus consistently requires "extraordinary circumstances" to preserve the finality of judgments. Rule 15(a)'s liberal amendment policy governs pretrial amendments and does not apply once a case is closed following a final judgment. The Second Circuit's "balancing" approach incorrectly conflates these separate inquiries and dilutes Rule 60(b)(6)'s well-established stringent standard. A party must first satisfy Rule 60(b) on its own terms, demonstrating extraordinary circumstances regardless of what they intend to do if the case is reopened, before Rule 15(a)'s amendment standard can apply. The District Court's determination that plaintiffs failed to demonstrate any extraordinary circumstances, considering that intervening legal developments rarely constitute such circumstances and that movants must generally be faultless in delay, fell within its discretion and was based on the correct legal standard.
Concurring in part and concurring in the judgment - Jackson, J.
Justice Jackson agreed with the majority's conclusion that the Rule 60(b)(6) standard, rather than the Rule 15(a) standard, applies when a district court considers a movant’s desire to amend a complaint in the context of a motion to reopen a case, and that the District Court did not abuse its discretion in denying reopening. However, Justice Jackson expressed disagreement with the District Court's reasoning for faulting plaintiffs for making a "deliberate choice" to appeal the dismissal of their complaint in lieu of accepting pre-dismissal opportunities to cure purported pleading deficiencies. She argued that declining to amend and instead diligently pursuing a statutory right to appeal does not categorically preclude Rule 60(b)(6) relief under Ackermann v. United States. A plaintiff's choice to appeal, even if overconfident about their pleading's strength, is not abandonment and should not be treated as precluding relief, particularly when a clear, intervening change in the law might supply the necessary "extraordinary circumstances." Denying reopening on this basis risks undermining the right to appellate review and leaving important legal questions unanswered.
Analysis:
This decision significantly reinforces the finality of judgments, establishing a higher bar for litigants seeking to reopen dismissed cases, even when subsequent appellate rulings clarify the underlying legal standards. It clarifies the proper sequential application of the Federal Rules of Civil Procedure, firmly separating Rule 60(b)'s stringent standard from Rule 15(a)'s liberal amendment policy in post-judgment contexts. The ruling will likely compel plaintiffs to exhaust all potential amendment opportunities at the trial court level, as appealing an initial dismissal 'with prejudice' and subsequently seeking Rule 60(b)(6) relief to amend is now an even more challenging legal path. This limits avenues for relief based on evolving legal interpretations unless truly extraordinary and faultless circumstances can be demonstrated.
