The U.S. Supreme Court recently reaffirmed the stringent standards applied to Rule 60(b)(6) of the Federal Rules of Civil Procedure, as demonstrated in the case of BLOM Bank SAL v. Honickman. This ruling emphasizes the necessity of “extraordinary circumstances” for reopening a judgment through the rule’s catchall provision, pushing back against a proposed more lenient standard for amending complaints after judgment.
Rule 60(b) outlines five specific reasons to reopen a judgment, while its subsection, Rule 60(b)(6), serves as a catchall for any other justifiable reasons. In the mentioned case, victims of Hamas attacks over two decades ago sought damages from a Lebanese bank under a federal statute aimed at financial institutions connected to terrorism. Their amended complaints were initially dismissed due to insufficient evidence of the bank’s awareness of terrorist activities. The U.S. Court of Appeals for the 2nd Circuit suggested a more lenient approach, citing a policy of allowing complaint amendments liberally.
Justice Clarence Thomas delivered the unanimous opinion, criticizing the 2nd Circuit’s relaxed view by outlining that Rule 60(b)(6) is intended for narrow applications, citing previous case law in Klapprott v. United States and Ackermann v. United States. The court distinguished between individuals lacking resources or representation and those capable of making deliberate legal choices. Justice Thomas stressed the importance of allowing litigation to reach a definitive end.
The decision underscores the separation of procedures at different litigation stages, particularly between liberal amendments under Rule 15(a) and post-judgment cases governed by Rule 60(b)(6). Despite hopes for more flexibility, the court set clear boundaries, demanding that any plea to reopen a case via Rule 60(b)(6) must be supported by extraordinary circumstances rather than the intentions of amendments post-judgment. For further details, please refer to the original report on SCOTUSblog.