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case_law | United States Federal

BLOM Bank SAL v. Honickman

Summary

Relief under Federal Rule of Civil Procedure 60(b)(6) requires extraordinary circumstances, and this standard does not become less demanding when the movant seeks to reopen a case to amend a complaint; a party must first satisfy Rule 60(b) before Rule 15(a)’s liberal amendment standard can apply.

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  • #1

    PRELIMINARY PRINT Volume 605 U. S. Part 1 Pages 204–222 OFFICIAL REPORTS OF THE SUPREME COURT June 5, 2025 REBECCA A. WOMELDORF reporter of decisions Page Proof Pending Publication NOTICE: This preliminary print is subject to formal revision before the bound volume is published. Users are requested to notif…

  • #2

    ciples with Rule 15(a)'s liberal amendment policy. Held: Relief under Rule 60(b)(6) requires extraordinary circumstances, and this standard does not become less demanding when the movant seeks to reopen a case to amend a complaint. A party must frst satisfy Rule 60(b) before Rule 15(a)'s liberal amendment standard…

  • #3

    that Rule 60(b)(6) “should only be applied in `extraordinary circum- stances.' ” Liljeberg v. Health Services Acquisition Corp., 486 U. S. 847, 864. Foman v. Davis, 371 U. S. 178, does not suggest otherwise. Foman dealt with Rule 59(e), which does not threaten the fnality of judgments to the same degree that Rule …

  • #4

    Fed. Rule Civ. Proc. 60(b)(6). We have consistently held that only “extraordinary circumstances” can justify relief under the Rule 60(b)(6) catchall. The question presented is whether this rigorous standard applies when a Rule 60(b)(6) movant seeks to reopen a case for the purpose of fling an amended complaint. W…

  • #5

    awareness . . . elemen[t] necessary to plead JASTA aiding- and-abetting liability.” 432 F. Supp. 3d 253, 257 (EDNY 2020). In the District Court's view, “it [was] not enough for Page Proof Pending Publication 208 BLOM BANK SAL v. HONICKMAN Opinion of the Court Plaintiffs to plausibl[y] allege that BLOM was genera…

  • #6

    2022 WL 1062315, *3 (EDNY, Apr. 8, 2022). The District Court denied their request. Specifcally, it rejected plaintiffs' contention that “the Second Circuit's clar- ifcation of the aiding-and-abetting standard” constituted “ `extraordinary circumstances' ” suffcient to justify relief under Rule 60(b)(6). Ibid. Tha…

  • #7

    motion to vacate and amend as calling for two distinct analy- ses, requiring Plaintiffs to successfully navigate Rule 60(b)'s fnality gauntlet before they could invoke Rule 15(a)'s lib- eral repleading policy.” Ibid. We granted certiorari. 603 U. S. 949 (2024). II Relief under Rule 60(b)(6) requires extraordinar…

  • #8

    Walker, 533 U. S. 167, 174 (2001) (internal quotation marks omitted); see also Fischer v. United States, 603 U. S. 480, 493 (2024) (avoiding an “unbounded interpretation” of catchall provision that would “render superfuous” a “reticulated list” of provisions). Thus, we have repeatedly held that relief under Rule …

  • #9

    phasized the importance of a Rule 60(b)(6) movant's fault- lessness, explaining that “[t]here must be an end to litigation someday, and free, calculated, deliberate choices are not to be relieved from.” Id., at 198; see also, e. g., 12 J. Moore, D. Coquillette, G. Joseph, G. Vairo, & C. Varner, Moore's Federal Pr…

  • #10

    case is closed and there is no pending pleading to amend. Accord, e. g., Boyd v. Secretary, Dept. of Corrections, 114 F. 4th 1232, 1237 (CA11 2024) (“[O]nce the court has entered fnal judgment, Rule 15(a) no longer applies and no amend- ment is possible unless the judgment is frst set aside”). A contrary approach…

  • #11

    ment standard that the party will eventually have to meet if the Rule 60(b) motion is granted. What a district court may not do is what the Second Circuit demanded here: dilute Rule 60(b)(6)'s stringent standard by “balanc[ing]” it with “Rule 15(a)'s liberal pleading principles.” 2024 WL 852265, *2. Page Proof Pe…

  • #12

    Opinion of the Court Rule 60(b)(6) does, we do not require a movant to show the same “extraordinary circumstances” to receive relief. See Foman, 371 U. S., at 181–182. III We also disagree with the Second Circuit's disposition of this case. District courts' Rule 60(b) rulings are reviewed “only for abuse of dis…

  • #13

    Justice Jackson, concurring in part and concurring in the judgment. I join all but Part III of the Court's opinion. I agree with the Court's conclusion that, when a district court considers “a movant's desire to amend his complaint” in the context of a motion to reopen a case under Federal Rule of Civil Proce- d…

  • #14

    voiding or satisfaction of a judgment. Fed. Rules Civ. Proc. 60(b)(1)–(5). Then, under paragraph (6), a court may, “[o]n motion and just terms,” reopen a judgment, order, or pro- ceeding for “any other reason that justifes relief,” Rule 60(b)(6), provided that the motion is fled “within a reason- able time,” Rule…

  • #15

    its perceived “small likelihood of . . . success” was not enti- tled to reopening under Rule 60(b)(6) where he could not otherwise demonstrate extraordinary circumstances. Po- lites v. United States, 364 U. S. 426, 432–433 (1960). More recently, we found reopening inappropriate when a movant had “abandoned any at…

  • #16

    486 U. S., at 863, n. 11; cf. Buck v. Davis, 580 U. S. 100, 123– 126 (2017) (holding that the use of race-based considerations at sentencing in a capital case was an extraordinary circum- stance warranting reopening even though the movant's coun- sel had introduced the evidence in question). The bottom line, juri…

  • #17

    (Sotomayor, J., concurring) (detailing this Court's “settled Page Proof Pending Publication 222 BLOM BANK SAL v. HONICKMAN Opinion of Jackson, J. precedents” recognizing “the availability of Rule 60(b)(6) to reopen a judgment in extraordinary circumstances, including a change in controlling law”). To treat the p…

  • #18

    include adjustments to formatting, captions, citation form, and any errant punctuation. The following additional edits were made: None