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BLOM Bank SAL v. Honickman

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Supreme Court of the United States
BLOM Bank SAL v. Honickman
Term: 2024
Important Dates
Argued: March 3, 2025
Decided: June 5, 2025
Outcome
reversed
Vote
9-0
Majority
Clarence Thomas • Chief Justice John Roberts • Samuel Alito • Sonia Sotomayor • Elena Kagan • Neil Gorsuch • Brett Kavanaugh • Amy Coney Barrett
Concurring
Ketanji Brown Jackson

BLOM Bank SAL v. Honickman is a case that was decided by the Supreme Court of the United States on June 5, 2025, during the court's October 2024-2025 term. The case was argued before the Court on March 3, 2025.

The Court reversed the decision of the United States Court of Appeals for the Second Circuit, in a 9-0 ruling, holding that Rule 60(b) applies even when requesting to reopen a case to amend, and "extraordinary circumstances" are required to reopen a case. Justice Clarence Thomas delivered the majority opinion of the court. Justice Ketanji Brown Jackson filed an opinion concurring in part and the judgment.[1] Click here for more information about the ruling.

HIGHLIGHTS
  • The issue: The case concerned aiding-and-abetting liability under the Justice Against Sponsors of Terrorism Act (JASTA). Click here to learn more about the case's background.
  • The questions presented: "Whether Rule 60(b)(6)'s stringent standard applies to a post-judgment request to vacate for the purpose of filing an amended complaint."[2]
  • The outcome: The U.S. Supreme Court reversed the decision of the U.S. Court of Appeals for the Second Circuit.


    • The case came on a writ of certiorari to the United States Court of Appeals for the Second Circuit. To review the lower court's opinion, click here.

    Background

    Case summary

    The following are the parties to this case:[3]

    • Petitioner: BLOM Bank SAL
      • Legal counsel: Michael Hugh McGinley (Dechert LLP)
    • Respondent: Michal Honickman, et al.
      • Legal counsel: Michael Jacob Radine, (Osen LLC)

    Honickman, et al. brought their case against BLOM Bank SAL under the Anti-Terrorism Act, as amended by the Justice Against Sponsors of Terrorism Act (JASTA) for allegedly aiding Hamas by providing financial services to customers affiliated with the organization. They claimed that BLOM was liable for aiding and abetting terrorism through these financial services.[4] Hamas—Ḥarakat al-Muqāwamah al-ʾIslāmiyyah, or The Islamic Resistance Movement—was designated by the U.S. government as a foreign terrorist organization in 1997.[5]

    The following summary of the case was published by Oyez:[4]

    “ 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)).[6] ”


    To learn more about this case, see the following:

    Timeline

    The following timeline details key events in this case:

    Questions presented

    The petitioner presented the following questions to the court:[2]

    Questions presented:
    “ Whether Rule 60(b)(6)'s stringent standard applies to a post-judgment request to vacate for the purpose of filing an amended complaint.[6] ”

    Oral argument

    Audio

    Audio of oral argument:[8]




    Transcript

    Transcript of oral argument:[9]

    Outcome

    The Court reversed the decision of the United States Court of Appeals for the Second Circuit, in a 9-0 ruling, holding that Rule 60(b) applies and requires "extraordinary circumstances," even when requesting to reopen a case to amend. Justice Clarence Thomas wrote the majority opinion of the court.

    Opinion

    Justice Thomas wrote in the opinion of the court:[1]

    “ Federal Rule of Civil Procedure 60(b) permits a district court to grant relief from a final judgment in limited circumstances. The Rule includes five provisions setting out specific grounds upon which parties may seek such relief [...] It also includes a catchall provision that allows a district court to relieve a party from a final judgment for 'any other reason that justifies relief.' Fed. Rule Civ. Proc. 60(b)(6). We have consistently held that only 'extraordinary circumstances' can justify relief under the Rule 60(b)(6) catchall. The question presented is whether this rigorous standard applies when a Rule 60(b)(6) movant seeks to reopen a case for the purpose of filing an amended complaint. We hold that it does.[6] ”

    Concurring

    Justice Ketanji Brown Jackson wrote an opinion, concurring in part and in judgment:[1]

    “ I join all but Part III of the Court’s opinion...

    I write separately to emphasize that our affirmance of the District Court’s denial of reopening in this case does not require accepting all aspects of the District Court’s reasoning. In particular, I think the District Court was wrong to fault plaintiffs for making a “deliberate choic[e]” to appeal the dismissal of their complaint in lieu of accepting various predismissal opportunities to cure purported pleading deficiencies... The District Court based that aspect of its reopening determination on our opinion in Ackermann v. United States. But, as I explain below, the “choice” that plaintiffs made—declining to amend—does not categorically preclude Rule 60(b)(6) relief under that precedent.[6]

    		”

    Text of the opinion

    Read the full opinion here.

    October term 2024-2025

    See also: Supreme Court cases, October term 2024-2025

    The Supreme Court began hearing cases for the term on October 7, 2024. The court's yearly term begins on the first Monday in October and lasts until the first Monday in October the following year. The court generally releases the majority of its decisions in mid-June.[10]


    See also

    External links

    Footnotes

    1. ↑ 1.0 1.1 1.2 Supreme Court of the United States, "BLOM BANK SAL, PETITIONER v. MICHAL HONICKMAN, ET AL.," June 5, 2025
    2. ↑ 2.0 2.1 Supreme Court of the United States, "23-1259 BLOM BANK SAL V. HONICKMAN QP", October 4, 2024
    3. ↑ Supreme Court of the United States, ""No. 23-1259,""accessed November 19, 2024
    4. ↑ 4.0 4.1 Oyez, "BLOM Bank SAL v. Honickman," accessed November 19, 2024
    5. ↑ U.S. State Department, "Foreign Terrorist Organizations," accessed November 19, 2024
    6. ↑ 6.0 6.1 6.2 6.3 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
    7. ↑ United States Court of Appeals for the Second Circuit, Honickman v. BLOM Bank SAL, February 29, 2024
    8. ↑ Supreme Court of the United States, "Oral Argument - Audio," argued March 3, 2025
    9. ↑ Supreme Court of the United States, "Oral Argument - Transcript," argued March 3, 2025
    10. ↑ SupremeCourt.gov, "The Supreme Court at Work: The Term and Caseload," accessed January 24, 2022
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