United States Court of Appeals for the Second Circuit · 1944 · Civil Procedure
139 F.2d 774 (2d Cir. 1944)
Updated
Civil ProcedureRule 8(a)Rule 12(b)(6)notice pleadingshort and plain statementclaim upon which relief can be grantedpro se pleadingliberal construction
Facts
The plaintiff, acting without a lawyer, alleged grievances against the Collector of Customs arising from the handling and auction sale of imported bottles of medicinal tonics from Italy. He claimed that two cases disappeared while in the collector's custody and that, at the auction, the collector sold the remaining merchandise to another bidder using the plaintiff's bid of $110 rather than the other bidder's price of $120. The complaint suggested the collector had held the goods for about a year and then sold them at public auction, apparently as unclaimed merchandise. The plaintiff sought $5,000 in damages against the defendant individually and as collector.
Issue
Whether the plaintiff's amended complaint, though inartfully drafted, stated a claim upon which relief could be granted so as to survive dismissal on the face of the complaint under the Federal Rules of Civil Procedure.
Rule
Under the Federal Rules of Civil Procedure, a complaint need not state facts sufficient to constitute a cause of action; it need only contain a short and plain statement of the claim showing that the pleader is entitled to relief. On a motion to dismiss directed only to the face of the complaint, the court must give the plaintiff the benefit of reasonable intendments in the allegations and may dismiss only if no claim upon which relief can be granted is stated.
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One of 10 multiple-choice questions for this case. Pick an answer to see why.
Elena Cruz, acting without a lawyer in Miami, files a federal complaint against a port warehouse supervisor. In awkward, fragmented sentences, she alleges that the supervisor caused three crates of her fabric dye to disappear and released the remaining crates to another bidder at an announced public sale despite her earlier matching bid; she seeks damages. The supervisor moves to dismiss under Rule 12(b)(6) solely because the complaint does not plead detailed facts establishing each element of a cause of action.
How should the court rule on the motion?
Explanation. Under the majority opinion, the Federal Rules do not require pleading 'facts sufficient to constitute a cause of action.' Rule 8(a) requires only a short and plain statement showing entitlement to relief, and a Rule 12(b)(6) motion aimed only at the face of the complaint should be denied if the allegations, liberally read, disclose a potentially valid claim.