布洛姆银行诉霍尼克曼案

Victims and families of Hamas terrorist attacks between 2001 and 2003 sued BLOM Bank SAL under the Anti-Terrorism Act, alleging the Lebanese bank aided and abetted the attacks by providing financial services to Hamas-affiliated customers. The District Court dismissed the complaint with prejudice, finding insufficient allegations of general awareness. The Second Circuit affirmed, though noting the district court applied too stringent a standard. Plaintiffs then moved under Rule 60(b)(6) to vacate the judgment and file an amended complaint. The District Court denied the motion; the Second Circuit reversed, holding courts must balance Rule 60(b) finality principles with Rule 15(a)'s liberal amendment policy. The Supreme Court granted certiorari, heard oral argument on March 3, 2025, and issued its decision on June 5, 2025.

The Supreme Court unanimously reversed the Second Circuit, holding that relief under Rule 60(b)(6) requires extraordinary circumstances, and this standard does not become less demanding when the movant seeks to reopen a case to amend a complaint. A party must first satisfy Rule 60(b) before Rule 15(a)'s liberal amendment standard can apply. The Court remanded for further proceedings. BLOM Bank was awarded $21,812.34 in costs.

Whether the "extraordinary circumstances" standard under Federal Rule of Civil Procedure 60(b)(6) becomes less demanding when a movant seeks to reopen a final judgment for the purpose of filing an amended complaint, or whether district courts must instead balance Rule 60(b)'s finality principles against Rule 15(a)'s liberal amendment policy.

The decision establishes an important precedent for all civil cases in the federal system, reaffirming the finality of judgments and clarifying that the stringent Rule 60(b)(6) extraordinary circumstances standard cannot be diluted by Rule 15(a)'s liberal amendment policy. This unanimous ruling provides clarity for litigants and courts regarding post-judgment motions to reopen and amend complaints, discouraging strategic litigation tactics where plaintiffs deliberately decline amendment opportunities only to seek reopening after an adverse ruling.