Blom Bank Sal v. Honickman

Questions presented

SCOTUS records, cert granted 4 Oct 2024

For more than 70 years, this Court has "required a movant seeking relief under Rule 60 (b)(6)" of the Federal Rules of Civil Procedure "to show 'extraordinary circumstances' justifying the reopening of a final judgment." Gonzalez v. Crosby, 545 U.S. 524, 535 (2005) (quoting Ackermann v. United States, 340 U.S. 193, 199 (1950)). This Court has also stressed that a movant must be "faultless" to obtain relief. Pioneer Inv. Servs. v. Brunswick Assocs. Ltd. P'ship, 507 U.S. 380, 393 (1993). "This very strict interpretation of Rule 60(b) is essential if the finality of judgments is to be preserved." Gonzalez, 545 U.S. at 535 (cleaned up). In this case, Respondents declined multiple invitations and opportunities to amend their complaint. The District Court then dismissed their complaint with prejudice, and the Second Circuit affirmed. Only then did Respondents move to vacate the judgment so they could file an amended complaint. The District Court denied the motion under Rule 60(b)(6)'s well-settled standard. But the Second Circuit reversed, based on an unprecedented "balanc[ing]" test that requires district courts to consider Rule 15(a)'s "liberal pleading principles" when addressing a Rule 60 (b)(6) motion to reopen a judgment for the purpose of filing an amended complaint. The question presented is: Whether Rule 60(b)(6)'s stringent standard applies to a post-judgment request to vacate for the purpose of filing an amended complaint.

Opinion summary

Etalia.ai summary of the majority opinion

The US Supreme Court case involved Blom Bank SAL, a Lebanese bank, and its alleged role in facilitating terrorist activities by providing financial services to Hezbollah. The plaintiffs were victims of Hezbollah attacks who argued that the bank's actions violated the Anti-Terrorism Act (ATA) by knowingly supporting terrorism. The central issue was whether Blom Bank's provision of routine banking services constituted 'knowing' support for terrorism under the ATA. The court ruled in favor of Honickman, finding that while banks can be held liable under the ATA for aiding and abetting terrorism, there must be clear evidence showing they had actual knowledge their services would further terrorist acts. In this instance, it was determined that merely offering standard banking operations without direct intent or awareness did not meet this threshold.