Supreme Court of the United States
Blom Bank Sal v. Honickman
June 5, 2025605 U.S. 204
Summary
The Court, in an opinion by Justice Thomas, held that a party seeking to reopen a final judgment under Rule 60(b)(6) to amend a complaint must establish extraordinary circumstances before invoking Rule 15(a)'s liberal amendment standard. Courts may consider amendment-related circumstances but may not dilute Rule 60(b)(6) by balancing it against Rule 15(a). The Court also held that the District Court acted within its discretion in denying reopening, reversed the Second Circuit, and remanded. Justice Jackson joined all but Part III and concurred in the judgment, without any other Justice joining her separate opinion. She agreed that the intervening clarification of law did not require reopening, but disputed treating plaintiffs' deliberate decision to appeal rather than amend as a persuasive additional justification for denying relief.
Holding
- The standard governing Rule 60(b)(6) motions seeking reopening to amend a complaint.. A party must satisfy Rule 60(b)(6)'s extraordinary-circumstances requirement before Rule 15(a)'s liberal amendment standard applies; the two standards may not be balanced to weaken the reopening requirement.
- Whether denial of reopening constituted an abuse of discretion.. The District Court did not abuse its discretion by denying plaintiffs' Rule 60(b)(6) motion.
Docket 23-1259
Cited authorities
- CA11
- Fed. R. Civ. P. 60(b)(6)
- Fed. R. Civ. P. 60(b)
- 18 U.S.C. § 2333
- 106 Nw. U. L. Rev. 377
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