Docket 23-1259
Blom Bank Sal v. Honickman
DecidedJun 5, 2025
8-0 (Jackson concurring in part)decision
Source: CourtListener.
Court rules strict "extraordinary circumstances" standard applies even when reopening a case to amend a complaint
What it does
The ruling holds that Rule 60(b)(6)'s demanding "extraordinary circumstances" standard for reopening a final judgment does not soften just because the person seeking to reopen the case wants to file an amended complaint. A party must first satisfy Rule 60(b)(6) on its own terms before Rule 15(a)'s more lenient amendment standard can even come into play. Lower courts may not blend or balance the two standards together.
Who benefits
Defendants in civil lawsuits (including corporations and financial institutions) benefit from stronger finality protections, since it becomes harder for plaintiffs to reopen a dismissed case just to try again with new allegations after losing on appeal.
Who is affected
Plaintiffs whose complaints were dismissed with prejudice, especially those who initially declined the chance to amend before final judgment, are affected because they face a higher bar to reopen their case afterward, even if an appeals court later clarifies the legal standard in a way that might have helped them.
Practical impact
District courts nationwide must treat requests to reopen final judgments for the purpose of amending a complaint as requiring full satisfaction of Rule 60(b)(6)'s strict extraordinary-circumstances test first, without blending in Rule 15(a)'s liberal amendment policies. This makes it harder for plaintiffs who lost a case on the merits, especially after declining earlier chances to amend, to get a second chance to replead based on a later, more favorable appellate clarification of the law.
Majority reasoning
The majority reasoned that Rule 60(b)(6) is a narrow catchall provision available only in extraordinary circumstances, a standard the Court has consistently applied since Klapprott v. United States and reaffirmed in many later cases, because a looser standard would let parties circumvent the time limits built into Rule 60(b)'s other provisions and undermine the finality of judgments. It held that Rule 60(b)(6) and Rule 15(a) apply at different litigation stages and require separate inquiries, so a court must first find extraordinary circumstances under Rule 60(b)(6) before Rule 15(a)'s liberal amendment policy can apply at all. The majority rejected the Second Circuit's approach of "balancing" the two rules because doing so would necessarily dilute Rule 60(b)(6)'s strict standard. It also found Foman v. Davis inapplicable because that case involved Rule 59(e), which does not threaten judgment finality the way Rule 60(b)(6) does. Applying the deferential abuse-of-discretion standard, the majority concluded the District Court properly denied relief because an intervening change in legal interpretation rarely counts as extraordinary circumstances and the plaintiffs had made repeated deliberate choices not to amend their complaint.
Constitutional question
The case asked whether the strict "extraordinary circumstances" standard for reopening a final court judgment under Federal Rule of Civil Procedure 60(b)(6) becomes less demanding when the person asking to reopen the case wants to amend their complaint, given Rule 15(a)'s more relaxed standard for amending pleadings before trial.
Precedent changed
The ruling rejects the Second Circuit's "balancing" approach that blended Rule 60(b)(6)'s finality standard with Rule 15(a)'s liberal amendment policy, holding it inconsistent with the Court's established Rule 60(b)(6) precedents including Klapprott, Ackermann, and Liljeberg.