Docket 23-1259
Blom Bank Sal v. Honickman
DecidedJun 5, 2025
9-0unanimous decision
Source: CourtListener.
Court rules strict "extraordinary circumstances" standard applies even when reopening a case to amend a complaint
What it does
The Court holds that Rule 60(b)(6)'s demanding "extraordinary circumstances" standard applies in full even when a party's goal in reopening a final judgment is to amend their complaint. A party must first satisfy Rule 60(b)(6) on its own terms before Rule 15(a)'s more lenient amendment standard can ever come into play; the two rules cannot be blended or "balanced" together.
Who benefits
Defendants and other parties who have obtained final judgments in their favor benefit from continued finality, since plaintiffs cannot use a desire to amend as a way to soften the strict standard for reopening closed cases.
Who is affected
Plaintiffs and other litigants who lost their case, had it finally dismissed, and later want to reopen the judgment to fix their pleadings are affected, because they must clear the high extraordinary-circumstances bar before any amendment can be considered.
Practical impact
Litigants seeking to reopen closed federal cases to fix defective complaints must now clearly show extraordinary circumstances under Rule 60(b)(6) before any amendment can be considered, regardless of how sympathetic their amendment request might otherwise be. This forecloses the more flexible "balancing" approach some circuits, including the Second Circuit, had used, making it harder for plaintiffs whose cases were dismissed with prejudice to get a second chance after later favorable appellate clarifications of legal standards.
Majority reasoning
The Court reasoned that Rule 60(b)(6) is a narrow catchall available only when the first five grounds for relief don't apply, and that a broad reading would let parties circumvent the one-year time limits attached to those other grounds. Longstanding precedent, starting with Klapprott v. United States and reaffirmed many times since, requires "extraordinary circumstances" for 60(b)(6) relief, and this strict standard exists to protect the finality of judgments. Because Rule 60(b) and Rule 15(a) operate at different stages of litigation, Rule 15(a)'s liberal amendment policy does not apply until after a judgment has already been reopened under Rule 60(b)(6)'s tougher standard. The Court rejected plaintiffs' reliance on Foman v. Davis because that case involved Rule 59(e), which does not threaten finality the way Rule 60(b)(6) does, so a Rule 59(e) movant need not meet the same demanding standard. Applying deferential abuse-of-discretion review, the Court found the District Court's denial of reopening was well justified because a mere clarification of legal standards on appeal is not an extraordinary circumstance and the plaintiffs had repeatedly made deliberate choices not to amend.
Constitutional question
Whether the strict "extraordinary circumstances" standard for reopening a final judgment under Federal Rule of Civil Procedure 60(b)(6) becomes less demanding when the person asking to reopen the case wants to file an amended complaint under Rule 15(a).
Precedent changed
The Second Circuit's "balancing" approach combining Rule 60(b)(6) finality principles with Rule 15(a)'s liberal amendment policy was rejected and is no longer good law in that circuit.