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Leatherman filed a civil rights action against Tarrant County Narcotics Intelligence and Coordination Unit, a municipal government unit. The district court, applying a heightened standard of pleading, granted a motion to dismiss the complaint. The United States Court of Appeals for the Fifth Circuit affirmed. The Supreme Court granted certiorari.
A heightened standard of pleading in civil rights cases alleging municipal liability under 42 U.S.C. 1983 does not comport with the liberal notice pleading standard of the Federal Rules of Civil Procedure.
Leatherman filed a civil rights action against a unit of municipal government, the Tarrant County Narcotics Intelligence and Coordination Unit, under 42 U.S.C. 1983. The basis alleged for municipal liability was the Tarrant County Narcotics Intelligence and Coordination Unit’s failure to adequately train police officers. The district court granted a motion to dismiss the complaint. The court applied a heightened standard of pleading. The United States Court of Appeals for the Fifth Circuit affirmed. The Supreme Court granted certiorari.
Can a federal court apply a heightened standard of pleading in civil rights cases alleging municipal liability under 42 U.S.C. section 1983?
No. A heightened standard of pleading, more stringent than the liberal notice pleading system set up by the Federal Rules of Civil Procedure, cannot be imposed by a federal court in civil rights cases alleging municipal liability under 42 U.S.C. 1983.
Federal Rule of Civil Procedure 8(a)(2)requires that a complaint contain only a short and plain statement of the claim showing that the pleader is entitled to relief. The Court (1) rejected Respondent’s argument that a heightened standard of pleading was not imposed in this case, and (2) noted that the Federal Rules did not impose any requirement of greater particularity for pleadings in this case.