Ashcroft v. Iqbal

Brief Fact Summary.

Respondent sued Petitioners for unconstitutional conditions of imprisonment. Petitioners moved to dismiss the claim for insufficient allegations of their involvement.

Synopsis of Rule of Law.

Under the plausibility standard, a claim has facial plausibility when the plaintiff pleads factual allegations that demonstrate more than a sheer possibility of unlawful conduct.

Facts.

Javaid Iqbal (Respondent), a citizen of Pakistan and a Muslim, was arrested following the September 11, 2001 terrorist attacks in the United States. Respondent brought charges against U.S. Attorney General Ashcroft and FBI Director Mueller (Petitioners) for the adoption of unconstitutional policies that subjected Respondent to harsh conditions of confinement based on his race, religion, or national origin. Petitioners filed a motion to dismiss for insufficient allegations of their involvement.

Issue.

Did Respondent sufficiently allege facts in his complaint that Petitioners adopted unconstitutional policies that deprived him of his rights?

Held.

No, Respondent did not plead a sufficient claim. The case is reversed and remanded to the Court of Appeals.

Dissent.

Justice Souter argues that Respondent’s complaint satisfies Rule 8(a)(2) because the factual allegations, taken as true, demonstrate that Petitioners were at the very least aware of the discriminatory policies. He argues that the Court improperly labels these allegations as conclusory.

Discussion.

Under Rule 8(a)(2), a complaint is sufficient if it contains a short and plain statement showing entitlement to relief. Entitlement to relief is determined by the plausibility standard established in Bell Atlantic v. Twombly. Here, the Court concludes Plaintiff did not provide sufficient facts alleging Petitioners adopted unconstitutional policies for the purpose of discriminating against detainees on the basis of race, religion, or national origin.