We'll hear an argument next this morning, case 231259, Bloom Bank versus Mikal Hanickman.

Mr. McKinley.

Mr. Chief Justice, and may it please the Court, this Court has long held that Rule 60B6 requires extraordinary circumstances to reopen a final judgment,

and those circumstances cannot be the

result of the movement's own strategic choices. The Second Circuit has diluted that

stringent standard. In its view, courts must also give effect to Rule 15A's liberal

repleting policy when considering a 60B6 motion seeking to replete.

That outlier view is wrong.

It has no basis in law or logic.

Rather than blurring the two rules, the proper approach is to keep them separate.

If this Court's well-settled test for 60B6 is met, then Rule 15 comes into play.

Collapsing the two steps undermines finality. It creates an inherently contradictory test.

It invites inefficient, repetitive, and costly litigation that is at odds with the Federal

Rule's overriding objectives. Here, respondents do not qualify for

Rule 60B6 relief. They declined multiple opportunities to amend their complaint in both the trial

court and on appeal. Instead, they made the tactical choice to stand on their pleadings,

even when the Second Circuit ordered supplemental briefing after the Kaplan decision.

As a result, they received a final judgment that was affirmed on appeal.

Now they seek to restart that process all over again.

Doing so would effectively treat the Second Circuit's original decision as an advisory opinion,

and respondents have offered no justification other than that they mistakenly believe

that their original complaint was sufficient.

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