BLOM Bank SAL v. Honickman
View Official PDFBelow are plain-language sections to help you understand what the Court decided in BLOM Bank SAL v. Honickman and why it matters. Quotes are taken from the syllabus (the Court’s short summary at the start of the opinion).
Summary
A short, plain-English overview of BLOM Bank SAL v. Honickman.
In BLOM Bank SAL v. Honickman, the Supreme Court addressed whether plaintiffs could amend their complaint under Rule 60(b)(6) after a final judgment. The Court emphasized that Rule 60(b)(6) requires 'extraordinary circumstances' and does not become less demanding when reopening a case to amend a complaint. The Second Circuit's balancing approach was rejected as it diluted the stringent standard of Rule 60(b)(6).
Holding
The single most important “bottom line” of what the Court decided in BLOM Bank SAL v. Honickman.
The 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.
Constitutional Concepts
These are the Constitution-related themes that appear in BLOM Bank SAL v. Honickman. Click a concept to see other cases that involve the same idea.
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Why Procedural Due Process is relevant to BLOM Bank SAL v. Honickman
The case involves the procedural standards for reopening a case under Rule 60(b)(6), which relates to fair procedures in the judicial process.
Syllabus excerpt (verbatim)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.
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Why Remedies and Relief is relevant to BLOM Bank SAL v. Honickman
The case discusses the limits on the types and scope of remedies a court may order, specifically the standards for granting relief under Rule 60(b)(6).
Syllabus excerpt (verbatim)A party must first satisfy Rule 60(b) before Rule 15(a)'s liberal amendment standard can apply.
Key Quotes
Short excerpts from the syllabus in BLOM Bank SAL v. Honickman that support the summary and concepts above.
Relief under Rule 60(b)(6) requires extraordinary circumstances.
The Rule 60(b)(6) standard does not change when a party seeks to reopen a case to amend a complaint.
Balancing the strict standards of Rule 60(b)(6) against the more relaxed standards of Rule 15 necessarily weakens the former.
