BLOM Bank SAL v. Honickman

Justia · Docket · oyez.org

Argued on Mar 3, 2025.

Petitioner: BLOM Bank SAL.
Respondent: Michal Honickman.

Advocates:

• Michael H. McGinley (for the Petitioner)
• Michael J. Radine (for the Respondents)

Facts of the case (from oyez.org)

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)).

Question

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?