June 5, 2025
The procedural rules that govern civil proceedings in federal trial courts are oriented toward a final but just resolution of every case brought before them. See Federal Rule of Civil Procedure 1. For that reason, Federal Rule of Civil Procedure 60(b) offers a limited number of narrow grounds for relief from a “final judgment.” The last one offers relief for “any other reason that justifies relief.” Fed.R.Civ.P. 60(b)(6). Earlier in the same set of procedural rules, Federal Rule of Civil Procedure 15 allows parties to amend their pre-trial pleadings with the court’s permission but requiring the court to “freely give” its permission “when justice so requires.” Fed.R.Civ.P. 15(a)(2).
In Blom Bank Sal v. Honickman (US SupCt Slip Opinion of June 5, 2025), the Court unanimously ruled that the two rules cannot be combined to justify relief from a “final judgment.” The Court ruled that once a “final judgment” has been rendered by a trial court, the narrow grounds for relief under Rule 60(b), including any narrowly drawn “other reason” under Rule 60(b)(6), must be met first, before any liberally drawn reasons for amending pleadings in an otherwise closed case can be considered.
Comment: The Court’s ruling and Opinion follow both the text and the structure of the Federal Rules of Civil Procedure as a whole. Although uncited by the Court, the overall statement of the Rules’ purpose at Federal Rule of Civil Procedure 1 compels the Court’s decision.
Dan D. Rhea
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