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Ashcroft v. Iqbal

Supreme Court of the United States · 2009 · Civil Procedure

Civil Procedurepleadingplausibility standardRule 12(b)(6)two-step analysisRule 8Rule 12(b)(6)plausibility

Facts

Iqbal, a Pakistani Muslim, was arrested after the September 11 attacks, detained, and classified as a person "of high interest," which resulted in confinement in restrictive ADMAX SHU conditions. In his Bivens complaint, he alleged that Ashcroft and Mueller adopted and approved a policy subjecting him to harsh confinement on account of race, religion, or national origin. As to those officials, the complaint alleged that Mueller directed the FBI's arrest and detention of thousands of Arab Muslim men and that Ashcroft and Mueller approved the policy of holding post-September-11 detainees in highly restrictive conditions until cleared by the FBI. The complaint further labeled Ashcroft the "principal architect" of the policy and Mueller "instrumental" in its adoption and implementation.

Issue

Whether the court of appeals had interlocutory jurisdiction to review the denial of the motion to dismiss based on qualified immunity, and whether Iqbal's complaint contained sufficient factual matter under Rule 8 to state a plausible Bivens claim that Ashcroft and Mueller purposefully discriminated against him on account of race, religion, or national origin.

Rule

Under Rule 8, a complaint must contain sufficient factual matter, accepted as true, to state a claim for relief that is plausible on its face. Courts evaluating a motion to dismiss should disregard legal conclusions and conclusory recitals not entitled to an assumption of truth, then determine whether the well-pleaded factual allegations plausibly give rise to an entitlement to relief. In Bivens and Section 1983 suits, officials are not liable on a respondeat superior theory; each defendant is liable only for his own misconduct, and for unconstitutional discrimination the plaintiff must plead purposeful discrimination, not mere knowledge.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In federal court in Chicago, Lena Ortiz sued a federal housing director under Bivens, alleging he violated her equal protection rights. Her complaint says the director was the "driving force" behind a discriminatory inspection program and "knowingly approved" targeting Latino tenants, but the only supporting facts are that the agency increased inspections after a rash of code violations in neighborhoods with many Latino residents.

On the director's Rule 12(b)(6) motion, how should the court analyze the complaint?

Explanation. Under the majority opinion, courts use a two-step approach. First, they identify and disregard legal conclusions and conclusory recitals not entitled to the assumption of truth. Second, they assume the well-pleaded factual allegations are true and determine whether those facts plausibly give rise to entitlement to relief. Labels such as "driving force" or bare assertions of knowing approval are not enough without factual support.