Brief Fact Summary.
Respondent sued Petitioners for unconstitutional conditions of imprisonment. Petitioners moved to dismiss the claim for insufficient allegations of their involvement.
Synopsis of Rule of Law.
Under the plausibility standard established in Bell v. Twombly, a claim only has facial plausibility when the plaintiff pleads factual allegations that demonstrate more than a sheer possibility of unlawful conduct.
In Bivens, the Supreme Court recognized for the first time an implied private action for damages against federal officers alleged to have violated a citizen's constitutional rights.View Full Point of Law
Javaid Iqbal (Respondent), a citizen of Pakistan and a Muslim, was arrested following the September 11, 2001 terrorist attacks in the United States. Respondent brought charges against U.S. Attorney General Ashcroft and FBI Director Mueller (Petitioners) for the adoption of unconstitutional policies that subjected Respondent to harsh conditions based on his race, religion, or national origin. Petitioners filed a motion to dismiss for insufficient allegations of their involvement.
Did Respondent sufficiently allege facts in his complaint that Petitioners adopted unconstitutional policies that deprived him of his rights?
No, Respondent did not plead a sufficient claim. The case is dismissed.
Justice Souter argued that Respondent’s complaint satisfied Rule 8(a)(2) because the factual allegations, taken as true, demonstrated that Petitioners were at the very least aware of the discriminatory policies. He argued that the Court improperly labeled these allegations as conclusory.
Under Federal Rules of Civil Procedure, Rule 8(a)(2), a complaint is sufficient if it contains a short and plain statement showing entitlement to relief. The Court concluded that entitlement to relief must be determined by the plausibility standard established in Bell v. Twombly. Here, the Court concluded Respondent did not provide sufficient facts alleging Petitioners adopted unconstitutional policies for the purpose of discriminating against detainees on the basis of race, religion, or national origin.