Case Info: BLOM Bank SAL v. Honickman | Case No. 23-1259 | Date Argued: 3/3/25

Link to Docket: Here.

Background:

For more than 70 years, this Court has "required a movant seeking relief under Rule 60(b)(6)" of the Federal Rules of Civil Procedure "to show 'extraordinary circumstances' justifying the reopening of a final judgment." Gonzalez v. Crosby, 545 U.S. 524, 535 (2005) (quoting Ackermann v. United States, 340 U.S. 193, 199 (1950)). This Court has also stressed that a movant must be "faultless" to obtain relief. Pioneer Inv. Servs. v. Brunswick Assocs. Ltd. P'ship, 507 U.S. 380, 393 (1993). "This very strict interpretation of Rule 60(b) is essential if the finality of judgments is to be preserved." Gonzalez, 545 U.S. at 535 (cleaned up).

In this case, Respondents declined multiple invitations and opportunities to amend their complaint. The District Court then dismissed their complaint with prejudice, and the Second Circuit affirmed. Only then did Respondents move to vacate the judgment so they could file an amended complaint.

The District Court denied the motion under Rule 60(b)(6)'s well-settled standard. But the Second Circuit reversed, based on an unprecedented "balanc[ing]" test that requires district courts to consider Rule 15(a)'s "liberal pleading principles" when addressing a Rule 60 (b)(6) motion to reopen a judgment for the purpose of filing an amended complaint.

Question Presented: Whether Rule 60(b)(6)'s stringent standard applies to a post-judgment request to vacate for the purpose of filing an amended complaint.

Oral Advocates:

• For petitioner: Michael H. McGinley, Washington, D. C.
• For respondents: Michael J. Radine, Hackensack, N. J.