E.I. Dupont de Nemours & Co. (Defendant) sought to dismiss Sierocinski’s (Plaintiff) lawsuit over a defective dynamite cap for failure to state a specific cause of action.
Federal Rule of Civil Procedure 8 only mandates that a plaintiff specify a short, simple statement of a claim under which the plaintiff would be entitled to relief.
Plaintiff filed a claim, alleging that Defendant had negligently manufactured and distributed dynamite caps which exploded when crimped. Plaintiff also alleged that Defendant knew that users would crimp the dynamite caps. Defendant moved to strike the complaint for a failure to state a specific act of negligence, claiming that it had no way of knowing what type of action it was defending. The motion was granted by the trial court.
Does Federal Rule of Civil Procedure 8 require only a short, simple statement of a claim under which the plaintiff would be entitled to relief?
(Biddle, J.) Yes. The Rule requires that a plaintiff allege a short, simple statement of a claim under which he would be entitled to relief. When the complaint alleges negligence in product manufacturing, the complaint does not need to include any specific act or theory of negligence. The allegation of negligence is enough to give the defendant notice as to the cause of action and the believed breach of duty. Defendant will develop more information to allow the preparation of a defense through interrogatories. Reversed and remanded.
No specific details need to be provided in order to comply with the Federal Rules, so long as the complaint gives fair notice to the defendant of the claim and upon what grounds it rests. A complaint only fails to state a cause of action if on its face the plaintiff can prove no facts supporting his claim which would allow him to prevail.