Brief Fact Summary. Plaintiff sued Defendant in federal court on vague allegations that Defendant stole Plaintiff’s merchandise and sold Plaintiff’s merchandise at a prohibited price. The District Court ordered Plaintiff to amend the complaint. Plaintiff alleged more facts and the District Court dismissed Plaintiff’s claim on the grounds that the complaint did not “state facts sufficient to constitute a cause of action.”
Synopsis of Rule of Law. A complaint need only state a claim upon which relief can be granted. It does not necessarily have to contain facts that can support a cause of action.
Issue. Did Plaintiff complaint need to contain “facts sufficient to constitute a cause of action”?
Held. No. Reversed and remanded. Plaintiff’s complaint need only contain a statement that shows he would be entitled to relief. The complaint is not clear but it does allege that Defendant took Plaintiff’s tonic and Defendant sold its tonic for less than a price Defendant allegedly was supposed to sell it. If Plaintiff proves these allegations, Plaintiff would be entitled to relief. Therefore, the complaint should not have been dismissed.
Discussion. This case illustrates the standard for evaluating a complaint against a motion to dismiss under Federal Rules of Civil Procedure 12(b)(6) (failure to state a claim upon which relief can be granted). This standard is known as “notice pleading.” A complaint need only state grounds which would entitle the plaintiff to relief. It need not contain specific allegations of facts that would constitute some specific cause of action. A complaint can be vague and incoherent, but if there is a discernable ground for relief, the complaint should not be dismissed for failure to state a claim.