In BLOM Bank SAL v. Honickman et al., the US Supreme Court held that relief under Federal Rule of Civil Procedure (FRCP) 60(b)(6) to vacate a final judgment requires a showing of extraordinary circumstances, and this rigorous standard does not become less demanding when a party seeks to reopen a case to amend a complaint. The Court emphasized that a party seeking to reopen a case after final judgment is rendered must first satisfy FRCP 60(b)’s requirements before the liberal amendment policy of FRCP 15(a) can apply, rejecting the Second Circuit’s approach of balancing these standards.
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Supreme Court: Extraordinary Circumstances Required to Vacate a Final Judgment Under Rule 60(b)(6) to File an Amended Complaint
