Doe v. Smith

Brief Fact Summary.

Doe sued Smith in federal district court, claimed that a video recording taken by Smith was an “unauthorized interception” in violation of federal wiretapping law. The district court dismissed the complaint because Doe failed to allege that the recording was an “interception.”

Synopsis of Rule of Law.

Pleadings in federal court need not allege facts corresponding to each element of a statute; they need not identify, and plead specifically to, each ingredient of a sound legal theory. Rather, they plead claims for relief.

Facts.

Doe sued Smith in federal district court, claiming that a video recording taken by Smith was an “unauthorized interception” and that its disclosure forbidden under federal wiretapping law.  Federal court jurisdiction was based on the federal wiretapping law. The district court dismissed the complaint because Doe failed to allege that the recording was an “interception” within the definition of that term under the applicable wiretapping law.

Issue.

Did the district court err in dismissing Doe’s complaint?

Held.

Yes. Although the complaint did not maintain that Smith “intercepted” anything, it was sufficient to state a claim for relief.

Discussion.

Plaintiffs usually need only to narrate their grievances so that defendants are apprised of the accusations against them. A complaint is sufficient if any facts consistent with its allegations, and showing entitlement to prevail, can be established by affidavit or by testimony at trial. Plaintiff satisfied this pleading requirement; her complaint did  not have to cover everything necessary for her to prevail, and factual details and legal arguments could be presented later.