Summary
The Supreme Court held that relief under Federal Rule of Civil Procedure 60(b)(6) requires extraordinary circumstances, and this standard does not become less demanding when a movant seeks to reopen a case to file an amended complaint. Rejecting the Second Circuit's balancing approach, the Court emphasized that Rule 60(b)'s stringent finality standard must be satisfied before Rule 15(a)'s liberal amendment policy can apply. The Court reversed the appellate judgment and remanded the case for further proceedings.
Topics
Practice areas
Questions Presented
- Whether Rule 60(b)(6) extraordinary‑circumstances standard applies when a movant seeks to amend a complaint after a final judgment.
- Whether a district court must first satisfy Rule 60(b)(6) before applying Rule 15(a)’s liberal amendment policy.
Holdings
- The extraordinary‑circumstances standard of Rule 60(b)(6) applies even when the movant seeks to reopen the case to amend the complaint.
- A district court must first satisfy Rule 60(b)(6) before any Rule 15(a) amendment analysis can be applied.
Key quotations
“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.” (at 5)
“The Rule 60(b)(6) standard does not change when a party seeks to reopen a case to amend a complaint. In that circumstance, satisfaction of Rule 60(b)(6) necessarily precedes any application of Rule 15(a).” (at 8–10)
Factual background
Plaintiffs, victims and families of Hamas terrorist attacks (2001‑2003), sued BLOM Bank SAL under the Anti‑Terrorism Act alleging the bank aided and abetted the attacks by providing financial services to Hamas‑affiliated customers. BLOM argued the complaint failed to state a claim and declined to amend.
Procedural history
The District Court dismissed the complaint with prejudice. The Second Circuit affirmed. The District Court denied a Rule 60(b)(6) motion to vacate. The Second Circuit reversed that denial. The Supreme Court reversed and remanded.
Remand instructions
The case is remanded for further proceedings consistent with this opinion.