The question
Whether the extraordinary-circumstances standard for relief from final judgment under Federal Rule of Civil Procedure 60(b)(6) becomes less demanding when the movant seeks to reopen a case in order to amend a complaint.
BLOM Bank SAL v. Honickman
What the Court decided
Reversed. The Court held that Rule 60(b)(6) relief always requires extraordinary circumstances, and that standard does not soften when a party seeks to reopen a closed case to file an amended complaint. A movant must first satisfy Rule 60(b) before Rule 15(a)'s liberal amendment standard can apply, because the two rules operate at different stages and require separate inquiries. The Second Circuit's balancing approach improperly diluted Rule 60(b)(6)'s stringent standard.
How the justices split
UnanimousThe Court's opinion
Thomas, joined by Roberts, Alito, Sotomayor, Kagan, Gorsuch, Kavanaugh, Barrett
Rule 60(b)(6) is a narrow catchall that provides relief from final judgment only in extraordinary circumstances, and that standard does not relax when the movant wants to reopen a case to amend a complaint. Satisfaction of Rule 60(b)(6) necessarily precedes any application of Rule 15(a), because the two rules govern different stages of litigation and require separate inquiries. Rule 15(a)'s direction to freely give leave to amend governs pretrial amendments and does not apply once a case is closed following final judgment. The Second Circuit's balancing approach is inconsistent with the Court's precedents because it dilutes Rule 60(b)(6)'s stringent standard.
Concurring in part and in the judgment
Jackson, writing alone
Jackson joined the Court's opinion as to all but Part III and filed an opinion concurring in part and concurring in the judgment, agreeing with the outcome while not joining the reasoning in Part III.
How we know · 5 sourced claims
The Court held that relief under Rule 60(b)(6) requires extraordinary circumstances, and that standard does not become less demanding when the movant seeks to reopen a case to amend a complaint.
Source: syllabus, Held
A party must first satisfy Rule 60(b) before Rule 15(a)'s liberal amendment standard can apply.
Source: syllabus, Held
The Court found the Second Circuit's balancing approach inconsistent with Rule 60(b)(6) because it improperly dilutes that rule's stringent standard.
Source: syllabus, Held
Thomas delivered the opinion of the Court, joined by Roberts, Alito, Sotomayor, Kagan, Gorsuch, Kavanaugh, and Barrett, and joined by Jackson as to all but Part III.
Source: syllabus, lineup
Jackson filed an opinion concurring in part and concurring in the judgment.
Source: syllabus, lineup