Ashcroft v. Iqbal

Brief Fact Summary.

Iqbal was detained in a maximum security unit after the September 11, 2001 attacks. He filed a complaint against Petitioners, federal officials, seeking damages for alleged deprivation of his  constitutional rights  while in custody. The district court denied the Petitioners’ motion to dismiss. The Court of Appeals affirmed.

Synopsis of Rule of Law.

A complaint must contain claims that are facially plausible in order to survive a motion to dismiss; i.e., there must be factual content sufficient to allow the court to reasonably infer that the defendant is liable.

Facts.

Iqbal was detained in a maximum security unit as a “person of high interest” after the September 11, 2001 attacks. He filed a complaint against Petitioners, federal officials, seeking damages for alleged deprivation of his  constitutional rights  while in custody. Iqbal’s complaint alleged that Petitioners subjected him to harsh conditions because of his race, religion or national origin. The district court denied Petitioners’ motion to dismiss. The Court of Appeals affirmed.

Issue.

Did Iqbal’s complaint plead sufficient facts to state a claim for purposeful and unlawful discrimination by Petitioners?

Held.

No. Iqbal’s complaint did not plead sufficient facts to state a claim for purposeful and unlawful discrimination by Petitioners.

Dissent.

Justice Souter

The dissent argued that because of Petitioners’ concession that they would be liable if they had actual knowledge of discrimination by their subordinates and exhibited deliberate indifference to that discrimination, the complaint satisfied Federal Rule of Civil Procedure 8(a)(2).

Justice Breyer

Joining in the dissent, Justice Breyer added that discovery management tools could be used to manage and prevent concerns over unwarranted litigation.

Discussion.

Because of the conclusory nature of Iqbal’s allegations, they were not entitled to the presumption of truth. Iqbal failed to “nudge” his claims to the category of “plausible.” The court also rejected Iqbal’s arguments that (1) the Court’s decision in Twombly should be limited to pleadings made in the context of an antitrust dispute; (2) the court’s construction of Federal Rule of Civil Procedure 8 should be relaxed because the court of appeals promised Petitioners minimally intrusive discovery; and (3) the federal rules require courts to credit a complaint‘s conclusory allegations.