BLOM Bank SAL v. Honickman
In brief
A party cannot reopen a closed case to amend its complaint unless it first shows extraordinary circumstances under Rule 60(b)(6).
- Where it stands
- Decided
Decided 9-0 · June 5, 2025 · Opinion by Justice Thomas
- What it’s about
- The Supreme Court held that a party seeking to reopen a final judgment under Federal Rule of Civil Procedure 60(b)(6) must demonstrate extraordinary circumstances, even if their goal is merely to file an amended complaint.
- Who it affects
- The decision protects the finality of judgments and makes it harder to revive a dismissed case simply by proposing a new complaint.
Summary: written with AI from the case record.
What it's about
The Court rejected the argument that the more lenient standard for amending pleadings under Rule 15(a) should relax the strict requirements for vacating a judgment.
The case addresses how courts balance giving parties a chance to fix pleadings against preserving final court judgments.
Question presented
Does Federal Rule of Civil Procedure 60(b)(6)’s stringent standard apply to a post-judgment request to vacate for the purpose of filing an amended complaint?
What the Court decided
Holding
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 vote
- Joined the judgment
- Concurred in a separate opinion
- Wrote an opinion
- Majority · 8joined the Court's opinion
- Concurring · 1agreed with the result, wrote separately
- Jacksonwrote separately
From the opinions
“A party must first satisfy Rule 60(b) before Rule 15(a)’s liberal amendment standard can apply.”
What's next
Lower courts must apply Rule 60(b)(6)'s extraordinary-circumstances requirement before considering whether an amended complaint should be allowed under Rule 15(a). Parties seeking to revive closed cases will need to meet that higher threshold.
Why it matters
For example, a plaintiff whose case was dismissed cannot rely on Rule 15(a)'s liberal standard without first meeting Rule 60(b)(6)'s extraordinary-circumstances test.
Documents
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More questions
- What did the Supreme Court rule in BLOM Bank SAL v. Honickman?
- The Court said parties must show extraordinary circumstances to reopen a final judgment under Rule 60(b)(6), even if they want to amend a complaint.
- Who won BLOM Bank SAL v. Honickman?
- BLOM Bank SAL prevailed. The Court affirmed that reopening required the strict Rule 60(b)(6) standard before any amendment request could be considered.
- How does BLOM Bank SAL v. Honickman affect plaintiffs with dismissed cases?
- They cannot use the liberal amendment rule alone to revive a closed case. They must first show extraordinary circumstances warranting reopening.
- Is Rule 15(a)'s liberal amendment standard still the law after BLOM Bank SAL v. Honickman?
- Yes. But it applies only after a party first satisfies Rule 60(b) when seeking to reopen a final judgment.
- What happens next after BLOM Bank SAL v. Honickman?
- Lower courts will apply the Court's rule in future reopening requests. Parties must show extraordinary circumstances before courts consider amended complaints.
Sources
Primary materials plus reporting. Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.