Ashcroft v. Iqbal

Brief Fact Summary.

Iqbal was arrested on immigration charges and detained in an investigation following the 9/11 terrorist attacks. He filed a complaint against federal officials alleging that he was deprived of federal constitutional rights  while in custody. The district courts denied the Petitioners’ motion to dismiss. The Court of Appeals affirmed.

Synopsis of Rule of Law.

To survive a motion to dismiss, a complaint must state a plausible claim for relief.

Facts.

Iqbal was arrested on immigration charges and detained following the September 11, 2001 terrorist attacks. He alleged that he was abused while in custody.  As to the Petitioners, specifically, Iqbal alleged that they adopted an unconstitutional policy and willfully and maliciously agreed to subject him to harsh conditions of confinement because of his race, religion, or national origin. The district court denied Petitioners’ motion to dismiss. The Court of Appeals affirmed, holding that the complaint adequately detailed allegations that, if true, would constitute constitutional law violations.

Issue.

Did the allegations contained in the complaint entitle Respondent to relief; i.e., did the claims, as pleaded, cross the line from conceivable to plausible?

Held.

No. The complaint did not contain sufficient allegations of fact to “nudge” Respondent’s claim of purposeful discrimination across the line from conceivable to plausible.

Dissent.

Justice Souter

The dissent argued that the factual allegations taken as true would establish that Petitioners knew of and condoned a discriminatory policy carried out by their subordinates, or, at the least, that the Petitioners were aware of a discriminatory policy and were deliberately indifferent about it.

Discussion.

Respondent had to plead and prove that Petitioners acted with discriminatory purpose. Respondent failed to nudge his claims of invidious discrimination across the line from conceivable to plausible because of (1) the conclusory nature of the allegations; (2) the allegations in the complaint did not plausibly suggest an entitlement to relief; and (3) the complaint did not contain facts plausibly showing Petitioners’ purposeful adoption of a policy of “high interest” classification of post-9/11 detainees, based on their race, religion, or national origin.