Post-judgment relief
BLOM Bank SAL v. Michal Honickman
Date: June 5, 2025
Issue: Whether the Federal Rule of Civil Procedure 60(b)(6) applies to a post-judgment request to vacate to file an amended complaint.
Case Summary: In a unanimous decision written by Justice Clarence Thomas, the U.S. Supreme Court ruled that relief under Federal Rule of Civil Procedure 60(b)(6) applies only in “extraordinary circumstances,” even where the movant seeks to reopen a case to file an amended complaint.
In 2019, victims and families of victims of Hamas terrorist attacks sued BLOM Bank SAL, alleging it aided and abetted the attacks by providing financial services to three customers allegedly associated with Hamas in violation of the Justice Against Sponsors of Terrorism Act (JASTA). BLOM Bank argued respondents failed to plausibly allege it was aware of a link between the three customers and Hamas at the time the bank provided the services. The Eastern District Court of New York invited respondents to amend their complaint on multiple occasions, but respondents chose to proceed with the complaint as pled.
Judge Kiyo Matsumoto dismissed the complaint with prejudice and denied plaintiffs’ leave to amend, ruling plaintiffs’ allegations were insufficient to state a JASTA claim. The court reasoned plaintiffs did not plausibly allege BLOM Bank assumed the role in Hamas’ terror activities by providing financial services to the three customers. The Second Circuit affirmed.
Eighteen months later, respondents moved to reopen the judgment under Rule 60(b)(6) to amend their complaint. Rule 60(b)(6) allows a court to relieve a party from a final judgment for “any other reason that justifies relief.” The district court denied the motion, concluding the Second Circuit’s clarification of the aiding-and-abetting foreseeability standard under JASTA did not qualify as “extraordinary circumstances.” The Second Circuit, however, reversed. It concluded district courts must weigh Rule 60(b)’s emphasis on finality alongside Rule 15(a)’s liberal standard for amending pleadings when plaintiffs seek to reopen a case to file an amended complaint. BLOM Bank then petitioned the U.S. Supreme Court for review, arguing Second Circuit’s approach conflicts with rulings from eleven other circuits and contradicts Supreme Court precedent. On Oct. 4, 2924, the Court granted certiorari.
The U.S. Supreme Court unanimously reversed, ruling a movant seeking to reopen a judgment and re-plead must first satisfy Rule 60(b) before Rule 15(a)’s liberal amendment standard can apply. The Court explained that Rule 60(b)(6) serves as a catchall provision, allowing relief from a final judgment for “any other reason that justifies relief,” beyond those listed in Rules 60(b)(1) through (5). The Court emphasized that both the rule’s text and structure limit this catchall to narrow circumstances. In the Court’s view, interpreting Rule 60(b)(6) too broadly would undermine the strict time limits in the other provisions and compromise the finality of judgments. The Court also clarified that this standard remains unchanged when a party seeks to reopen a case to amend a complaint, as Rule 60(b) must be satisfied before Rule 15(a) can be considered. The Court emphasized that Rule 15(a)(2)’s liberal amendment standard applies only before final judgment. Rejecting the Second Circuit’s balancing approach as inconsistent with Rule 60(b)(6) and precedent, the Court affirmed the district court properly found that BLOM Bank failed to show extraordinary circumstances and acted within its discretion in denying relief.
Bottom Line: The Supreme Court reaffirms the rigorous, independent standard that litigants must satisfy under Rule 60(b)(6) when they seek to reopen a final judgment.
Document: Opinion
