Facts of the Case

Provided by Oyez

This case involves victims and family members of HAMAS terrorist attacks who sued BLOM Bank SAL for allegedly aiding HAMAS by providing financial services to customers affiliated with the terrorist organization. The plaintiffs brought their case under the Anti-Terrorism Act, as amended by the Justice Against Sponsors of Terrorism Act (JASTA), claiming BLOM Bank was liable for aiding and abetting terrorism through these financial services.

The plaintiffs filed their initial complaint in January 2019, which the district court dismissed for failure to state a claim. On appeal, the U.S. Court of Appeals for the Second Circuit affirmed the dismissal but clarified that the district court had applied the wrong legal standard for aiding-and-abetting liability under JASTA. The plaintiffs then returned to the district court and moved to vacate the dismissal and amend their complaint. The district court denied their motion, and the Second Circuit concluded that the district court had erred by not properly balancing the competing principles of judgment finality (Rule 60(b)) and liberal pleading standards (Rule 15(a)).

Questions

  1. 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?

Conclusions

  1. A party seeking to reopen a final judgment under Federal Rule of Civil Procedure 60(b)(6) must show extraordinary circumstances, even if the goal is to file an amended complaint. Justice Clarence Thomas authored the 8-1 majority opinion of the Court.

    Relief under Rule 60(b)(6), a catchall provision for setting aside final judgments in exceptional cases, is available only in narrow circumstances not covered by other parts of the rule. This strict standard exists to uphold the finality of judgments and cannot be relaxed by reference to other procedural rules. Rule 15(a)(2), which allows liberal amendment of pleadings before trial, does not apply after final judgment has been entered. Therefore, if a litigant wishes to amend a complaint after dismissal with prejudice, the extraordinary-circumstances standard of Rule 60(b)(6) must be satisfied first, before any consideration is given to whether amendment should be permitted.

    The Second Circuit erred by suggesting that courts reopening a case to permit amendment should balance the strict standards of Rule 60(b)(6) against the more permissive amendment policy of Rule 15(a). Doing so improperly undermines Rule 60(b)(6)’s high threshold.

    Justice Ketanji Brown Jackson authored a concurring opinion, agreeing with the judgment and most of the majority’s reasoning but emphasizing that a litigant should not be categorically penalized under Rule 60(b)(6) for choosing to appeal rather than amend a complaint.