BLOM Bank SAL v. Honickman

In this case, the court considered this issue: 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?

The case was decided on June 5, 2025.

The Supreme Court held 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 opinion is presented here in its entirety, but with citations omitted. If you appreciate this episode, please subscribe. Thank you.