Conley v. Gibson

Brief Fact Summary.

Black employees bring suit against a local union for race discrimination and the defendants attempt to dismiss the complaint for failure to state a claim upon which relief may be granted.

Synopsis of Rule of Law.

A complaint is sufficient so long as the plaintiff sets forth an assertion upon which relief may be granted. Specific and detailed facts are not necessary to survive a motion to dismiss.

Facts.

Local Union no. 28 of the Brotherhood of Railway and Steamship Clerks entered into an agreement with the Texas and New Orleans Railroad to fire 45 Black employees under the guise of a force layoff. However, Local 28 made an agreement with the Railroad to lay the Black employees off and hire white employees in their place. They would sometimes rehire the Black employees but with a reduction in seniority. Black employees requested Local 28 numerous times to help stop the discriminatory firings, but Local 28 did not provide any help. The evidence also showed that Local 28 would provide protection for white employees but not Black ones. Plaintiffs filed a class action suit represented by Conley brought suit against Defendants Local 28 and directors including Gibson alleging discrimination in violation of Plaintiffs’ right under the Railway Labor Act to fair representation.

Issue.

Are general allegations without specific facts supporting them enough for a complaint to survive a motion to dismiss for failure to state a claim upon which relief can be granted?

Held.

Yes, general allegations without specific facts supporting them are enough for a complaint to survive a motion to dismiss for failure to state a claim upon which relief can be granted. Decision of the court of appeals is reversed and the case is remanded.

Discussion.

1. The plaintiff is not required to lay out a complete recitation of the facts supporting the claim.
2. The Federal Rules of Civil Procedure only require that the plaintiff provide a short and plain statement of the claim which will provide the defendant with fair notice and the grounds for the claim against them.
3. Plaintiffs in this case met this low bar requirement.
4. Their claim, that Brotherhood and Local 28 discriminatorily failed to represent them against the Railroad based on their race, is a claim upon which relief may be granted.
5. If Plaintiffs’ claims are true, it would clearly constitute race discrimination in violation of the Railway Labor Act.
6. A complaint should not be dismissed “unless it appears beyond doubt that the plaintiff can prove no set of facts in support of the claim that entitle him to relief.”
7. While the claims are not very detailed, they do provide Defendants with enough to give notice of the claim against them, meeting the requirements of FRCP 8.