Prince’s Briefcase: Ashcroft v. Iqbal (Glannon Civil Procedure)


Glannon Civil Procedure: Pleadings

Here is a case from my Civil Procedure course which explains the correct way to plead a claim. No longer will a court hear “Basic Pleadings” or grievance complaints like Dioguardi v. Durning. This is also known as the “Well-Pleaded” standard or the “Twombly” Standard

Case Name, Citation Number, Author
Ashcroft v. Iqbal, 556 U.S. 662 (2009), Supreme Court of The United States

prince's briefcase (princesdailyjournal)Procedural History
District court dismiss Iqbal’s motion, relying on the Conley Standard (like Dioguardi v. Durning but needs facts, Go to Notes) saying that there was no set of facts on which Iqbal would be entitled to relief; Iqbal appealed the decision. The Court of Appeals then found that the pleading was adequate and said that the Twombly rule (enough to show claim is plausible, Go to Notes) does not apply universally–meaning only a few cases (Iqbal was straightforward: race discrimination). Supreme Court then granted certiorari–meaning they heard the case.

Facts
–Iqbal was a citizen of Pakistan and got arrested and detained by federal officials (Ashcroft) were investigating the 9/11 terrorist attacks
–Iqbal was supposedly tortured and claimed that his treatment while in detention violated his constitutional rights.
–Iqbal sued FBI Director Mueller, and Attorney General Ashcroft
–Iqbal claims that the FBI designated him because of his race, religion, and national origin.
–There was a statistic which showed thousands of Arab Muslim men being arrested and detained

Issue
Did Iqbal adequately plead his claim of injustice and racial discrimination?

Holding
No

Rule
An allegation is “well-pleaded” when it is more than a “mere conclusory statement”—more than just a “threadbare recital of the elements of the cause of action.”

Reasoning
–Iqbal’s case was a restatement of an element in the discrimination claim= It was conclusory and generic. This is not enough for the court to hear your claim.
–Iqbal need to give facts plausibly showing that Ashcroft purposefully detained him because of his race, religion, or national origin. There was nothing to show for it.
–The court will still accept the factual allegations of the complaint as true but only if the court can assume its veracity.
–His pleading contained no facts–just a basic grievance to grant him relief under the law.

Disposition
Reversed and Remanded to lower court

Notes
–Conley Rule: “a complaint should not be dismissed for failure to state a claim, unless it appears beyond doubt that the plaintiff can prove no set of facts in support of his claim which would entitle him to relief.
–Twombly Rule: Plaintiffs must allege enough to show that their claim is “plausible” not just conceivable
–There was no jury trial because the claim was not “well-pleaded”. The Judge(s) gave the verdict and not the jury
–Dissenting opinion: The court isn’t supposed to consider whether the allegations are probably true–they are supposed to take them as true. Meaning Judges can’t enforce red-tape!

Prince’s Takeaway
A plaintiff must not only show that Defendant violated her rights, but must also allege supporting evidence of the violations. PLEAD THE “FACTS CONSTITUTINTG A CAUSE OF ACTION” RATHER THAN LEGAL CONCLUSIONS. HERESAY or the Race Card won’t cut it.
–Courts and lawyers cite Ashcroft v. Iqbal over 100 times!
–if there was an email that showed Ashcroft purposefully detaining Iqbal and other Arab Muslim men, then Iqbal’s claim would have a case!

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