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. Reversing the Second Circuit, the Court ruled that district courts must apply Rule 60(b)'s stringent standard independently rather than balancing it against Rule 15(a)'s liberal amendment policy. The case was remanded for further proceedings consistent with this opinion.
Topics
Practice areas
Questions Presented
- Whether Rule 60(b)(6) extraordinary‑circumstances requirement applies when a movant seeks to amend a complaint.
- Whether a district court must balance Rule 60(b)(6) with Rule 15(a) in such a context.
Holdings
- The extraordinary‑circumstances standard of Rule 60(b)(6) applies even when the movant seeks to reopen the case to amend the complaint; the Rule 60(b)(6) inquiry must be satisfied before any Rule 15(a) amendment analysis.
- A district court must not balance Rule 60(b)(6) with Rule 15(a); the two rules apply at different stages and the Rule 60(b)(6) standard controls the vacatur inquiry.
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.” (5-6)
“The Second Circuit’s disposition of this case was incorrect. District courts’ Rule 60(b) rulings are reviewed only for abuse of discretion.” (11-12)
Factual background
Plaintiffs, victims and families of Hamas‑linked terrorist attacks between 2001 and 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 allege the requisite general awareness for aiding‑and‑abetting liability.
Procedural history
The Eastern District of New York dismissed the complaint with prejudice for lack of a pleading showing general awareness. The Second Circuit affirmed. The district court denied a Rule 60(b)(6) motion to vacate the judgment so plaintiffs could amend. The Second Circuit reversed, holding the district court must balance Rule 60(b)(6) with Rule 15(a). The Supreme Court reversed the Second Circuit.
Remand instructions
Remand for further proceedings consistent with this opinion.