Ashcroft v. Iqbal

Brief Fact Summary.

Plaintiff was arrested on criminal charges and detained by federal officials following the terrorist attack on 9/11. He filed suit against federal officials on the ground that his custody’s conditions infringed on his constitutional rights. The defendants moved the court to dismiss the complaint on grounds of failure to state a claim.

Synopsis of Rule of Law.

A complaint must allege non-conclusory facts that, if taken as true, state a claim to relief that is plausible on its face.

Facts.

Plaintiff was arrested and detained during the investigation of the 9/11 terrorist attacks. Plaintiff sued Defendants in district court, claiming that the conditions of the custody violated the First and Fifth Amendments. The complaint accused Defendant Ashcroft of being the “principal architect” and Defendant Mueller of being “instrumental” in the implementation of a discriminatory policy of confining individuals in harsh conditions based solely on their “religion, race, and/or national origin.” Defendants Ashcroft and Mueller claimed qualified immunity and moved to dismiss Plaintiff’s complaint for failure to state a claim. The district court denied the motion to dismiss. On appeal, the United States Court of Appeals for the Second Circuit affirmed after considering whether the complaint satisfied the plausibility standard set forth in Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007). The Second Circuit held that Plaintiff had alleged enough facts to allow the case to proceed. Defendants Ashcroft and Mueller petitioned the United States Supreme Court for a writ of certiorari, which was granted.

Issue.

Are conclusory allegations that high-ranking government officers knew of or condoned allegedly unconstitutional acts by subordinate officials sufficient to state a claim for unlawful discrimination?

Held.

No. The court held that Plaintiff failed to plead sufficient facts to state a claim for unlawful discrimination, because he only made conclusory allegations in his complaint and did not allege sufficient facts to show that the defendants implemented their policies for the purpose of discrimination.

Dissent.

Justice Souter, Stevens, Ginsburg, and Breyer

The dissent argued that in accordance with the judgment in Twombly, non-conclusory allegations should be accepted as true unless they are so incredible as to be obviously untrue. The majority tried to determine whether the allegations were true, rather than simply whether they were plausible. Furthermore, the main points of the complaint were non-conclusory. They pointed out that Defendants admitted that they would be liable if they knew their subordinates’ conduct was deliberately discriminatory. This suggested that Plaintiff did plead sufficient facts to state a claim for unlawful discrimination. Therefore, the complaint was therefore sufficiently supported by facts to be facially sufficient.

Bryer wrote separately to emphasize that the lower court had other tools that are designed to prevent unwarranted interferences and that can structure discovery in ways that diminish the risk of imposing unwarranted burdens on public officials.

Discussion.

A complaint must allege non-conclusory facts that, if taken as true, state a claim to relief that is plausible on its face. The plausibility determination is left to the trial court’s judgment. Although the facts in the complaint must be taken as true, the court is not required to afford legal conclusions the same deference. Even if an allegation is not supported by facts to the point of probability, the court requires more than conclusory statements. The court may begin its inquiry by determining which allegations need not be taken as true. Additionally, FRCP Rule 8 sets forth the basic requirements for pleadings in any civil action, and the Supreme Court’s interpretation of the rule in Twombly is applicable to all such actions regardless of subject matter. Even though a plaintiff may plead subjective knowledge and intent “generally” under FRCP Rule 9(b), this does not negate the requirements of Rule 8. In short, to be well-pleaded, a complaint must be supported by allegations containing factual content which leads to the conclusion given, and have factual and plausible arguments which cannot be easily disproved.

Here, Plaintiff did not make the required showing of plausibility. He pleaded that the federal government had adopted a policy detaining all Arab Muslims after the terrorist attack of 9/11, until they were individually declared non-criminal by the FBI. It was claimed that this policy owed its origin to Defendant Ashcroft and its adoption and widespread usage to Defendant Mueller. However, the allegation did not have factual content that would enable the court to come to the reasonable conclusion that Defendants were liable for the alleged misconduct. In fact, there were other, more reasonable, alternative explanations. Additional facts were needed to take the complaint from conceivable to plausible. Moreover, the allegations were mere conclusions, which need not be accepted as true. Because he failed to plead sufficient facts to show that the defendants implemented their policies for the purpose of discrimination, he failed to state a claim for unlawful discrimination. Therefore, the decision was reversed and the case remanded for the district court to determine whether Plaintiff may amend his complaint.