Ashcroft v. Iqbal

Brief Fact Summary.

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.

Synopsis of Rule of Law.

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.

Facts.

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.

Issue.

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?

Held.

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.

Dissent.

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.

Discussion.

1. Facially plausible means that the facts allow for a “reasonable inference” that the defendant is liable.
2. Plausibility is determined in the trial court.
3. While the facts must be taken as true, the court is not required to accept conclusory statements.
4. The court can begin its inquiry by determining which allegations do not need to be taken as true.
5. In this case Plaintiff Iqbal’s allegation that Defendants Ashcroft and Mueller had knowledge and intent are not unlikely, but they conclusory and do not need to be taken as true.
6. Also, even though Plaintiff Iqbal’s claims of discrimination are consistent with his other claims, there are other reasonable alternative explanations for what he alleges.
7. While Plaintiff Iqbal’s claims against the other defendants are able to proceed, the claims against Ashcroft and Mueller do not show anything more than a desire to keep suspects accused of terrorism under close watch.
8. More facts are needed to take the complaint from conceivable to plausible.
9. FRCP 8 states the basic requirements for pleadings in civil actions, and the Court’s ruling in Twombly is applicable to all cases regardless of subject matter.
10. Although Plaintiff Iqbal can plead subjective knowledge and intent generally under FRCP 9(b), this does not override FRCP 8’s requirements.
11. Plaintiff Iqbal has not made the requisite showing of plausibility and the complaint does not state a claim against Ashcroft and Mueller.