BLOM Bank SAL v. Honickman

Background

A group of people who were injured or lost family members in Hamas terrorist attacks between 2001 and 2003 sued an international bank, saying the bank helped Hamas by providing financial services to customers tied to the group. The bank asked a trial court to dismiss the case. Plaintiffs told the court they would not try to fix the complaint. The trial court dismissed the case with prejudice, finding the complaint did not show the bank had the necessary awareness of wrongdoing.

Reasoning

The plaintiffs appealed and then later asked the trial court to reopen the final judgment so they could file a revised complaint after an appeals court clarified the legal standard. The trial court denied that request, saying the appeals court’s clarification was not the kind of “extraordinary” reason needed to reopen a final judgment, and noting plaintiffs had declined earlier chances to amend. The court of appeals said judges should balance finality against a liberal rule for amendments. The Supreme Court rejected that balancing. It held that the strict “extraordinary circumstances” test for reopening final judgments always applies first; only if that test is met can the court consider allowing an amended complaint.

Real world impact

The decision makes it harder to reopen closed civil cases simply to fix a complaint. It confirms that changes in law do not automatically allow reopening, and it lets trial judges decline reopening when a plaintiff declined prior opportunities or lacks strong prospects.

Dissents or concurrances

A separate opinion agreed with the result but warned courts not to punish plaintiffs who reasonably appealed rather than amend, emphasizing that appeal choices do not always show fault.