Blom Bank Sal v. Honickman et al.
No. 23-1259 · Decided June 5, 2025 · Reversed and remanded
Does the "extraordinary circumstances" standard required for relief under Federal Rule of Civil Procedure 60(b)(6) apply when a party seeks to reopen a case specifically to file an amended complaint? The Court held that the "extraordinary circumstances" standard of Federal Rule of Civil Procedure 60(b)(6) applies when a party seeks to reopen a case to amend a complaint, and this standard must be satisfied before the liberal amendment policy of Rule 15(a) can be considered.
Vote & lineup9–0 (unanimous) on the judgment. Thomas delivered the opinion of the Court, joined by Roberts, Alito, Sotomayor, Kagan, Gorsuch, Kavanaugh, Barrett, Jackson (9). Concurrence(s): Jackson.
The question
Does the "extraordinary circumstances" standard required for relief under Federal Rule of Civil Procedure 60(b)(6) apply when a party seeks to reopen a case specifically to file an amended complaint? Specifically, the Court considers whether this rigorous standard is diluted by the liberal amendment policy found in Federal Rule of Civil Procedure 15(a). The Court must determine if a district court should "balance" these two rules or apply them sequentially.
Petitioner's argument
- Relief under the Rule 60(b)(6) catchall provision requires a showing of "extraordinary circumstances" to preserve the finality of judgments.
- The liberal amendment policy of Rule 15(a) governs pretrial amendments and does not apply once a case is closed following a final judgment.
- A party must first satisfy the stringent requirements of Rule 60(b) before any application of Rule 15(a)'s standard can occur.
- The Second Circuit's "balancing" approach improperly weakens the established strict standard for vacating a final judgment.
Respondent's argument
- When a party seeks to vacate a judgment specifically to file an amended complaint, district courts should give due regard to both Rule 60(b)'s philosophy of finality and Rule 15(a)'s liberal amendment policy.
- The two rules should be considered "in tandem" rather than as separate, sequential hurdles.
- This approach is consistent with the spirit of the Federal Rules of Civil Procedure, which favor resolving disputes on their merits.
- They rely on *Foman v. Davis* to suggest that technicalities should not prevent a party from amending their complaint.
The decision
- The Court held that relief under Rule 60(b)(6) requires "extraordinary circumstances," and this standard remains demanding even when the movant seeks to reopen a case to amend a complaint.
- Rule 60(b)(6) is a catchall provision for "any other reason that justifies relief" and must be interpreted narrowly to avoid circumventing the time limitations of Rules 60(b)(1)–(5), as noted in *Liljeberg v. Health Services Acquisition Corp.*
- The Court relied on *Klapprott v. United States* and *Ackermann v. United States* to establish that "extraordinary circumstances" are required to justify reopening a case, emphasizing the importance of the movant's faultlessness.
- The Court reasoned that Rule 60(b) and Rule 15(a) apply at different stages of litigation; Rule 15(a)(2)'s direction to "freely give leave when justice so requires" governs pretrial amendments but not cases closed by final judgment.
- A party must first satisfy the requirements of Rule 60(b)(6) before the liberal amendment standard of Rule 15(a) can be applied; therefore, a "balancing" approach is rejected as it dilutes the strict Rule 60(b)(6) standard.
- The Court distinguished *Foman v. Davis*, noting that it dealt with Rule 59(e), which does not threaten the finality of judgments to the same degree as Rule 60(b)(6).
- Applying an "abuse of discretion" standard from *Browder v. Director, Dept. of Corrections of Ill.*, the Court found the District Court's denial was justified because intervening legal developments rarely constitute extraordinary circumstances (*Agostini v. Felton*) and the respondents were not faultless in their delay (*Pioneer Investment Services Co. v. Brunswick Associates L. P.*).
Separate opinions
Jackson, concurring
- Argues that while the District Court did not abuse its discretion overall, it was wrong to fault respondents for making a "deliberate choice" to appeal rather than amend their complaint.
- Contends that choosing to exercise the statutory right to appeal under *Waetzig v. Halliburton Energy Services, Inc.* does not constitute "abandonment" of litigation as described in *Ackermann v. United States*.
- Asserts that a prior refusal to amend should not categorically preclude Rule 60(b)(6) relief if other extraordinary circumstances exist.