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Conley v. Gibson

Supreme Court of the United States · 1957 · Civil Procedure

pleadingnotice pleadingno set of facts standardRule 8Rule 12(b)(6)short and plain statementfair noticeno set of facts

Facts

Petitioners were Negro employees of the Texas and New Orleans Railroad at the Houston Freight House and were represented by Local 28 of the Brotherhood as the designated bargaining agent under the Railway Labor Act. They alleged that the Railroad purported to abolish 45 jobs held by Negro employees, but the jobs were actually filled by white employees after the Negro workers were discharged or demoted, with some Negroes later rehired at a loss of seniority. Petitioners further alleged that despite repeated pleas, the Union, acting according to plan, did nothing to protect them and refused to give them protection comparable to that given white employees. They sought declaratory, injunctive, and damages relief for the Union's discriminatory failure to represent them fairly.

Issue

Whether the federal courts lacked jurisdiction because the controversy fell within the exclusive jurisdiction of the National Railroad Adjustment Board, whether the railroad was an indispensable party, and whether the complaint failed to state a claim because it lacked specific factual detail. Also at issue was whether allegations that a union refused to protect Negro employees from discriminatory discharges stated a claim for breach of the union's statutory duty of fair representation.

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. Under the Federal Rules of Civil Procedure, a claimant need only provide a short and plain statement of the claim that gives the defendant fair notice of what the claim is and the grounds upon which it rests. Under the Railway Labor Act, a bargaining representative must represent all employees in the bargaining unit fairly and without racial discrimination, including in the administration of agreements and grievance handling.

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

In St. Louis, a group of Latino rail clerks sued their union, River Valley Transport Clerks Local 412, in federal court. Their complaint alleged that after layoffs, the union processed and pressed white members' seniority grievances but refused to assist Latino members because of ethnicity, and it sought damages and an injunction, but it did not identify every meeting, speaker, or date.

On the union's Rule 12(b)(6) motion arguing that the complaint is too conclusory because it lacks detailed evidentiary facts, how should the court rule?

Explanation. Under the majority opinion, the Federal Rules do not require a claimant to set out detailed facts. Rule 8(a)(2) requires only a short and plain statement that gives the defendant fair notice of the claim and the grounds on which it rests. A complaint should not be dismissed unless it appears beyond doubt that the plaintiffs can prove no set of facts entitling them to relief.