Man detained after 9/11 attempts to sue the former U.S. Attorney General and FBI Director for the harsh conditions he faced during his confinement.
In order to survive a motion to dismiss under Twombly, a complaint must have non-conclusory facts that, if taken as true, state a claim that is facially plausible.
Plaintiff Iqbal was detained during an investigation into 9/11. He claimed that the conditions he was held in violated the First and Fifth Amendments and he sued Defendants John Ashcroft, the U.S. Attorney General and Robert Mueller, the FBI Director at the time. Plaintiff Iqbal’s complaint alleged that Ashcroft was the “principal architect” and that Mueller was “instrumental” in implementing the discriminatory policy of confining inmates in harsh conditions based on their religion, race, and national origin. Both Defendants claimed qualified immunity and moved to dismiss for Plaintiff Iqbal’s failure to state a claim.
Under Twombly will a complaint survive a motion to dismiss if it does not have sufficient factual allegations to state a claim to relief that is facially plausible?
No, under Twombly, for a complaint to survive a motion to dismiss, it must allege sufficient facts that if taken as true “state a claim to relief that is plausible on its face”. Decision of the Court of Appeals for the Second Circuit is reversed and the matter is remanded for consideration as to whether Iqbal should be allowed to amend his complaint.
Justice Justice Souter with Justices Stevens, Ginsburg, and Breyer dissenting
At the motion to dismiss stage the court must accept the allegations as true. The court tested the factualness of Plaintiff Iqbal’s allegations instead of determining whether they were simply plausible. The majority also improperly looked at Plaintiff Iqbal’s allegations in isolation rather than viewing the complaint in its entirety.
Justice Justice Breyer dissenting
There are sufficient case-management tools available in discovery to “diminish the risk of imposing unwarranted burdens upon public officials” eligible for qualified immunity.